Data Privacy Policy

Effective Date: December 31,2019

This Scanbuy Data Privacy Policy (the “Privacy Policy”) outlines Scanbuy’s collection, use and sharing of consumer data for Scanbuy Data and describes consumer data protection rights, including a right to object to some of our processing. For information on data collected from users of Scanbuy websites and apps or that Scanbuy otherwise obtains in connection with managing our business, please see the Scanbuy Site Privacy Policy.

1. Who are we?

Scanbuy helps companies and organizations better understand and engage with consumers and markets by using online activity data collected from multiple sources across websites, mobile apps, and devices (including laptops and smartphones). Scanbuy Data (the “Service”) sorts the data we receive into categories based on consumers’ demographics, interests, and preferences (“Inference Data”); and makes it available to advertisers, website publishers, and content providers (collectively, our “Clients”) in order to facilitate interest-based advertising and provide a more relevant advertising experience to consumers. 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.

2. What information does Scanbuy hold?

Scanbuy collects information generally known as non-personally identifiable information (“Non-PII”) from third parties, such as from Scanbuy users directly, website publishers, mobile app developers, smart TV operators, and other providers of advertising technology (collectively, “Data Suppliers”) and services 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 (which may be derived from, for example, your device’s GPS, Bluetooth, or WiFi signals) 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 may also collect Non-PII such as age, gender, income, education, interests, and usage activity from third parties.

Notwithstanding the above, Scanbuy complies with its obligations under the California Consumer Privacy Act and the term “Personal Information” shall conform to the definition of California Civil Code Section 1798.140(o) throughout this Privacy Policy.

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 provides Clients standard categories of information in order to facilitate interest-based advertising and provide a more relevant advertising experience to consumers.

Scanbuy may process information it collects and/or creates, 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.

Hashed Emails: MD5 or SHA-1 hashing of the email address corresponding to a piece of DII

Location Information: Precise geolocation from or about a device (e.g., latitude-longitude coordinates).

Inference Data: Information drawn from the other categories of information in this table, created by Data Suppliers or by Scanbuy.

Demographic Data: Information that includes data such as age range or gender.

Behavioral Data: Information about the ways you use your device (e.g., consumer products information, events).

Scanbuy collects information from different Data Suppliers, some of which may constitute Personal Information. In the past twelve (12) months, Scanbuy has collected information about consumers from the following categories of Data Suppliers:

3. Data Collection Methods

Scanbuy, along with our Data Suppliers, use cookies, Web beacons, persistent device identifiers (e.g., Android ID), advertising identifiers (e.g., Google’s “Advertising ID,” Apple’s “IDFA”) and other technologies. These technologies are used for tracking, advertising, analytics and personalization and optimization of the Service. Additional details about our data collection practices and the different technologies we use to facilitate these activities can be found below:

Scanbuy and its Data Suppliers use cookies and similar technologies to assign you an anonymous user ID, in order to provide the Service. Consumers can delete or disable browser cookies through their browser. Choices made are browser and device specific. Please refer to your browser’s technical information for instructions on how to delete or disable cookies and other tracking technologies.

4. Cross-Device Matching

Scanbuy may use data we collect or receive from Data Suppliers 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.

5. How does Scanbuy use this data in its Service?

Generally, Scanbuy and our Clients use the data collected in order to gain better insights on consumers and allow our Clients to deliver more effective and relevant advertising and content to consumers. 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.

We may use and combine data collected from different sources, including data from third-party sources, to help create a more personalized advertising and online experience for consumers.

We may also use data about a user’s activity across multiple, unaffiliated third-party mobile apps to predict the types of ads that may interest the user. We share this data and data about a user’s visits to different websites with our Clients to identify an ad, a group of ads, or content to be displayed on a particular computer or device.

We may receive and create non-sensitive segments, like health/lifestyle, where we group categories of consumers by common traits and interests, to enable our Clients to deliver interest-based ads to consumers.

6. Does Scanbuy share Data

Scanbuy may disclose data collected through or in connection with the Service 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 Clients:

Currently, the Service is only performed on data collected and maintained within the United State, Canada and Mexico, however, all of the disclosures mentioned above may result in the international transfer of personal data to countries or regions with data protection laws that differ from those in a user’s country of residence. In cases where consumers’ personal data is transferred outside of their country of residence, we will ensure that there are adequate safeguards in place to protect their data.

7. Legal Basis

Applicable law in certain countries requires Scanbuy provide in this Scanbuy Data Privacy Policy the legal basis upon which we rely in order to process consumers’ data.

Scanbuy relies on one of the legal bases below in order to process consumers’ data:

8. How long does Scanbuy retain Data?

Scanbuy will retain your information for as long as you continue to interact with a Data Supplier. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Opt-Out and other Choices & Legal Rights

Scanbuy is committed to providing consumers 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 consumers’ choices and how they can exercise them.

(a) Web Browsers

Consumers may opt out of Scanbuy’s data collection and use of cookies for interest-based advertising purposes at any time. Consumers may also manage their advertising preferences in their web browsers by updating the interests and data that Scanbuy or its partners have associated with their browser(s).

After opting out, consumers will no longer be included in the target advertising activities conducted via the Service. 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 consumers on the browser on which they were installed, will only function as described if the consumer’s browser is set to accept third-party cookies, and may not be as reliable if the consumer’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/

(b) Mobile Apps

Mobile apps do not accept cookies, and as such the opt-out methods described above may not work for mobile apps. Consumers 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.

Consumers 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.

(c) Cross-Device Matching

Consumers 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 consumer has opted out using the tools described above, Scanbuy will honor any choice made by a consumer with regard to Scanbuy’s collection of data on any device(s) which had been matched to that consumer. It may be necessary to opt out separately on each device and browser that a consumer uses in order for their opt out choices to be reflected across all of their browsers and devices.

(d) Scanbuy Partners

Some of our partners’ Privacy Policies are available for your review, if you would like to review their Privacy Policies please visit the links below:

To view IRI’s Privacy Policy, click here.

To view Neustar’s Privacy Policy, click here.

To view Ameribase Digital’s Privacy Policy, click here.

To view Fysical’s Privacy Policy, click here.

To view zeotap’s Privacy Policy, click here.

To view PushSpring’s Privacy Policy, click here.

To view Oracle’s Privacy Policy, click here.

To view LiveRamp’s Privacy Policy, click here.

To view Nielsen’s Privacy Policy, click here.

To view Tradedesk’s Privacy Policy, click here.

To view Lotame’s Privacy Policy, click here.

To view TwineData’s Privacy Policy, click here.

To view Kochava’s Privacy Policy, click here.

To view FourSquare’s Privacy Policy, click here.

To view Safegraph’s Privacy Policy, click here.

To view OneAudience’s Privacy Policy, click here.

To view Revealmobile’s Privacy Policy, click here.

To view BDEX’s Privacy Policy,  click here.

To view Audience Acuity’s Privacy Policy, click here.

Some of Scanbuy’s partners provide opt-out tools which are cookie-based. If you would like to opt-out of the services of our Clients and/or Data Suppliers who provide such an opt-out mechanism, please visit the links below and follow the relevant instructions:

To opt-out of Oracle’s use of aggregate level and/or anonymous information, click here or here.

To opt-out of PushSpring’s use of aggregate level and/or anonymous information, click here.

To opt-out of Neustar’s use of information for their services, click: here for the use of cookies on Nuestar’s websites; here for Neustar’s services.

To opt-out of Fysical’s use of information for their services, click here.

(e) Scanbuy Choices

To opt-out of Scanbuy’s sale of Personal Information to third parties, click DO NOT SELL MY PERSONAL INFORMATION.

Depending on a consumer’s country of residence, under applicable law users may also have the right to:

Consumers 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 Services, 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.

(f) California Privacy Rights

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(e), (ii) call us at (844) 297-7265, 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.

10. Links to Third Party Websites and Services

For your convenience, we may provide links to third-party websites or services that are not governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by Scanbuy, we are not responsible for those websites or services content or information practices. We encourage you to review the privacy policies of any site or services before providing any personal information.

11. Children's Privacy?

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.

12. Data Security

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. 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.

13. Changes to this Privacy Policy

Scanbuy reserves the right to change this Privacy Policy from time-to-time. Be sure to check this page periodically for updates. If Scanbuy makes any changes to this Privacy Policy, we will update the “Effective Date” listed at the top of this page.

14. Contact Us

Please contact us with any questions or comments about this Scanbuy Data Privacy Policy or our privacy practices at: privacy@scanbuy.com or write to us at:

Scanbuy
10 E. 39th Street
Floor 10
New York, New York 10016
USA
Attn: Legal Dept.