Scalarr Privacy Policy

view archived version

Welcome to Scalarr privacy notice!

Scalarr, Inc. (hereinafter “Scalarr” or “We”) respects your privacy and is committed to protecting your personal data. This privacy notice (hereinafter “Privacy Policy”) will inform you as to how we look after your personal data when you visit, access or use our website located at: www.scalarr.io (hereinafter – “Website”) and/or services (as defined below) regardless of where you visit it from and tell you about your privacy rights and how the law protects you.

We respect the privacy of our partners, customers and their end users, and believe in enabling them to make informed choices about the use of their personal data, including by explaining our practices and providing appropriate ways to exercise their privacy rights. Taking the importance of your privacy into consideration, we have created and enacted this Privacy Policy to help you understand our privacy practices.

This Privacy Policy outlines our handling practices and how we collect and use the personal data you provide during your online and offline interactions with us and our Services. As used in this Privacy Policy, ”Personal Data“ means any information about an individual from which that person can be identified.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services.

By accessing or using our Services, you agree to this Privacy Policy. This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website or using our Services.

Scalarr’s Services

Scalarr’s Services enable mobile software publishers and/or developers (our “Customers”) to analyze data regarding their mobile advertising campaigns and detects unsolicited fraudulent installs.

Controller or Processor

In some instances, Scalarr may be a controller of Personal Data and responsible for your personal data, for example when you enter into a contract directly with us.

However, in most cases Scalarr has no direct relationship with its Customers’ End Users, or with any other individuals whose personal data we may process on our Customers’ behalf. Thus, in most of instances due to the nature of our business we act solely as data processor of Personal Data in respect to those parts of Personal Data we receive from our Customers when performing our contractual obligation with such Customer. For example, when we provide fraud detection services to our Customers basing on our contract with them. In such a case we are serving as data processor and act solely relying on instructions from such Customers.

Collection of your Personal Data

We collect several types of information from and about our partners, customers and their end users who visit our Website or use our Services via internet connection or through your device which you use to access our Services, including certain user details.

1. We collect the following categories of Personal Data about you when you use or otherwise interact with our Services or Website:

● Name

● Title

● Email address

● Home/work/mobile telephone number

● Postal or other physical address

● Logs and communication data

● Resources on our website which you access and use

● Facebook profile information (when you use Facebook to log-in to our Services or to create an account for our Services)

● IP addresses and other information collected passively through cookies, web-beacons and other tracking technologies.

2. End Users Data received from our Customers

Scalarr’s Customers use our Services to analyze the data regarding their mobile advertising campaigns and detects unsolicited fraudulent installs, and for such purpose upload to Scalarr’s service certain data regarding their End Users. Such data is provided to Scalarr by the Customer, by the Customer’s integration and implementation of Scalarr’s APIs into the Customer’s tracking-analytics system. The data we receive from Customers refers to downloads, clicks and installations of their mobile applications, mobile device use and data regarding in-app events and includes for example the following data: 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.

Once such data parameters are uploaded by our Customers to the Services, they enable us to provide the Services to our Customers and enable the Customers to analyze their mobile advertising campaigns and detects unsolicited fraudulent installs.

3. We collect and/or process your Personal Data in connection with the below activities related to our Services:

● Account registration

● Services features usage

● Use of certain Service

● Generating reports based on information collected from use of our Services

● Requesting service and support for our Services and providing such support

● Placing transactions or orders

● Registering to attend a seminar or webinar

● Participating in an online surveys

● Billing and collecting payments for our Services

● Registering for newsletter subscriptions

● Customizing the advertising and content you see

4. Cookies and Other Tracking Technologies

Scalarr and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information based on IP addresses. Users can control the use of cookies at the individual browser level.

Some third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie-policy.

5. Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data in this manner, you can request that your account be deactivated by contacting us as specified in the “Contact Us” section. If you would like to opt-out of receiving any information that you receive from us, you may update your email preferences by using the “UNSUBSCRIBE” link found in emails we send to you.

Processing of your Personal Data

The personal data collected or processed through our Services (concerning either our Customers, their End Users, our Partners or visitors to the Scalarr website) will be used for:

1. Processing your orders and providing you with access to the Site and the Services
2. Improving and maintaining our Services (e.g. for power predictive ML features)
3. Providing reports based on information collected from use of our Services
4. Communicating with you in relation to the purposes for which you provided your contact details and in relation to similar products or Services.
5. Keeping you up to date on the latest Service announcements, software updates and upgrades, system enhancements, special offers, and other related information
6. Providing and administer opt-in contests or other marketing or promotional activities on the scalarr.io or affiliate websites
7. Personalizing marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
8. Providing support and assistance for our Services
9. Providing the ability to contact you and provide you with shipping and billing information
10. Complying with our legal obligations, resolving disputes with users, enforcing our agreements
11. Creating aggregate data and anonymous data (as specified below)

By analyzing the data we receive, we may compile aggregate and anonymized data (“Aggregate Data”). Aggregate Data is anonymous and is not linked to any personal data. Aggregate Data helps understand trends and customer needs so that new services can be considered and so existing products and services can be tailored to customer desires.

Choices About How We Use and Disclose Your Information

You can choose whether to provide Personal Data to Scalarr, but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided.

1. Opt-out. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
2. Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
3. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Data Retention

How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.

We store your personal data on servers located within the European Union. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Sharing your Personal Data

We do not sell or rent your Personal Data in personally identifiable form to anyone.

We may share Personal Data within Scalarr (as described below), and with third party service providers for purposes of data processing or storage (as described in How We Protect Your Data Section).

We share your personal data within the Scalarr Group. This may involve transferring your data outside the European Economic Area.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguards is implemented:

• Where we use certain service providers outside the European Economic Area, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How We Protect Your Data

The security of your personal information is important to us. Scalarr is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure.

Whilst we take appropriate technical and organizational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us. We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Numerous studies have established that data stored in the cloud is less likely to be lost, deleted or leaked than data stored on a personal computer. All our data is fully encrypted at rest and in transit, and we employ state-of-the-art firewall and back-up technology. All our data is continuously backed up in several high security access-controlled data centers in different locations.

Your data is stored on one of the secure servers that we rent and we use the recommended industry practices to keep your data secure. We use appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.

We currently use Amazon Web Services by Amazon Web Services Inc., Hetzner Robot / Hetzner Cloud by Hetzner Online GmbH and Google Drive by Google LLC. (the " Hosting providers") to store your personal data. Those Hosting providers are in possession of various international security certificates that ensure safety of your data with them. You can read more on the security measures of Hosting providers at their official webpages.

If you have any questions about the security of your Personal Data, you can contact us at [email protected].

Linked websites and third party services

While navigating Scalarr's website or Services, you may be directed to content or functionality that is hosted by a third-party. When information is collected on behalf of Scalarr exclusively, Scalarr's Privacy Policy will be referenced and will govern how your information is used. For other, non-Scalarrs sites or services, the site/service owner's privacy policy will be referenced. You should review such third party’s privacy and security policies prior to use.

Commitment to Protecting Children’s Privacy

Scalarr does not knowingly collect or process personal data from or with respect to children under the age of 16, and you must be 16 years of age or older in order to establish an account for Scalarr’s Services.

If you are under 16, please do not attempt to use the Site or register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to us or use the Site or the Services. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible unless your parent or guardian has provided us with their consent for your use of our Site or Services.

If you are a parent or legal guardian and believe that your child under the age of 16 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.

Changes to Our Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. We encourage you to periodically review this page for the latest information on our privacy practices.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of your personal data

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing your personal data

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Right to withdraw consent

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us through contact details below.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Privacy Framework

Scalarr Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Scalarr Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Scalarr Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Scalarr Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) under the EU-US Data Privacy Framework (DPF) and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF (hereinafter altogether - “Framework). This means that we are committed to complying with the regulations and guidelines set forth by the FTC in order to ensure the protection of your personal data and privacy rights.

Individuals may have the possibility under certain conditions to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms above. For more information please see Annex I of the DPF Principles.

Under certain circumstances Scalarr Inc. may be required to disclose personal information in response to lawful requests by public authorities including to meet national security or law enforcement requirements.

Onward Transfers

Prior to disclosing Personal Information to a third party other than to an agent performing tasks on our behalf and pursuant to our instructions Scalarr Inc. will notify the relevant individual of the disclosure and allow the individual the choice to opt-out of the disclosure. We will ensure that any third party to which Personal Information is disclosed has agreed to use such Personal Information for only limited and specified purposes provides the same level of protection as required by the Framework and otherwise makes the commitments required by the Framework.

Scalarr Inc. accountability for Personal Information that it receives in reliance on the Framework and subsequently transfers to a third party is described in the Framework Principles. For Personal Information that Scalarr Inc. receives in reliance on the Framework and subsequently transfers to a third party for Processing Shionogi remains responsible and liable if the third party Processes the Personal Information in a manner inconsistent with the Framework Principles unless Scalarr Inc. proves that it is not responsible for the event giving rise to the damage.

Contact Us

To address your individual rights or if you have any privacy-related questions or comments related to this privacy policy, please send an email to [email protected]. You can also contact us by writing to this address: Scalarr Inc., 3500 South DuPont Hwy, Dover, DE 19901, USA.