Privacy Shield Policy

This Privacy Shield Policy (”Policy”) describes how Scalarr Inc. (”Company,” “we,” “us,” or “Scalarr”) receive and process certain personally identifiable information that we receive in the United States (“US”) from the European Economic Area (”EEA”) and Switzerland (”Personal Data”) under the Privacy Shield program. This Policy supplements Scalarr Privacy Policy located at https://scalarr.io/document/scalarr-privacy-policy/ (“Scalarr Privacy Policy”), and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Scalarr Privacy Policy.

Scalarr recognizes that the EEA and Switzerland has established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA and Switzerland. To provide adequate protection for certain Personal Data about our consumers and their end users received in the US from the EEA and Switzerland, Scalarr has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce (”Privacy Shield”). Scalarr adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the Privacy Shield, Scalarr is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review Scalarr representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list

Personal Data Collection and Use

Personal Data that is transferred to Scalarr from the EEA and Switzerland falls into the following categories:

Category 1. Personal Data from Scalarr’s customers’ end users in the EEA and Switzerland that Scalarr processes on behalf of its customers, such as: IP address, user agent, device identifiers such as: IDFA (Identifier For Advertisers iOS), Android ID, Google Advertiser ID (GAID), store platform, SDK version, anonymous User ID, timestamp Developer Key, application version, device model, manufacture, OS version, network status (WiFi/3G), post-install in-app events;

Category 2. Personal Data regarding personnel from Scalarr’s customers in the EEA and Switzerland, such as name, title, postal or other physical address, e-mail address, telephone number;

Category 3. Personal Data from subscribers of our newsletters and requests submitted through website Contact Us form such as name and e-mail address;

Category 4. Personal Data from visitors or our website https://scalarr.io, subscribers of our newsletters and requests submitted through Contact Us form such as IP addresses and other information collected passively through cookies, web-beacons and other tracking technologies.

We process Personal Data for the following purposes:

Category 1: to analyze the data regarding customer’s mobile advertising campaigns and detect unsolicited fraudulent installs of customers’ end users;

Category 2: for communications and maintenance of business relations with customers;

Category 3: to process individual requests and process individual newsletter subscriptions;

Category 4: to analyze trends and administer the website.

Scalarr will only process Personal Data in ways that are compatible with the purpose that Scalarr collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Scalarr maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

We do not collect any sensitive Personal Data.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions or services on our behalf such as data hosting, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your Personal Data is protected with the same level of protection the Privacy Shield requires.

Disclosures for National Security or Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

Scalarr maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your Personal Data to us at:

Email: [email protected]

Correspondence address: Scalarr Inc., 1013 Centre Road, Suite 403-B, Wilmington DE 19805, United States

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with JAMS. If you are unsatisfied with the resolution of your complaint, you may contact JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for further information and assistance.

Binding Arbitration

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Scalarr and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:

Email: [email protected]

Correspondence address: Scalarr Inc., 1013 Centre Road, Suite 403-B, Wilmington DE 19805, United States

Changes To This Policy

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.

Effective Date: January 15, 2020

Last modified: January 15, 2020