Privacy Policy

Last Updated May 7, 2021

Scanbuy understands that privacy is important to you. This Privacy Policy (“Policy”) explains how personal information about you is collected, used and may be disclosed by Scanbuy.  This Policy applies to information we collect when you use our websites, the ScanLife application, the Scanbuy code resolution platform and other online products and services where this Policy is posted (collectively, the "Services").  Please take the time to read through the Policy carefully, so that you can make informed choices concerning your personal information and can better protect your privacy and security.

Scanbuy reserves the right to change this Policy from time to time.  Be sure to check this page periodically for updates.  If Scanbuy makes any changes to this Policy, we will notify you by changing the “Effective Date” listed.  If Scanbuy makes any significant or substantial changes to this Policy, we will obtain your express consent prior to your continued use of the Services. Please be advised that failure to consent may result in the Services not functioning properly or not functioning at all.

1. Identification of the Data Processor

    ◦ The data provided by the user will be processed by SCANBUY INC., with registered     office 10 East 39th Street, 10th Floor, New York City, NY 10016 and VAT no.  E1610134160561 (hereinafter the “Responsible Party”) and other subsidiaries of the  SCANBUY GROUP for the purposes set out in section 2. You may contact the Person Responsible at our e-mail address legal@scanbuy.com

2. Group Subsidiaries 

  ◦ SCANBUY SPAIN, S.L. with registered office at Calle José Castán Tobeñas 1, 28020, Madrid,  and CIF B87664967.

  ◦ SCANBUY RETAIL, with registered office at Calle José Castán Tobeñas 1, 28020, Madrid, and CIF B87664967.

3. Securing your data

In accordance with the provisions of the regulations in force on personal data protection, the Data Processor undertakes to comply with all the applicable legal provisions, in particular with the GDPR and the LOPDGDD for the processing of personal data for which he is responsible, and clearly with the principles described in article 5 of the GDPR, by which they are processed in a lawful, loyal and transparent manner in relation to the data subject and are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The Responsible Party guarantees that it has implemented appropriate technical and organisational policies to apply the security measures established by the GDPR and the LOPDGDD in order to protect the rights and freedoms of USERS and has communicated to them the appropriate information to enable them to exercise these rights.

Scanbuy will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

Scanbuy will store all the personal information you provide on secure servers.

Information relating to electronic transactions entered into via this website will be protected by encryption technology.

No method of transmission over the Internet, or method of electronic storage, is 100 percent secure. While Scanbuy uses reasonable efforts to protect your information from unauthorized access, use or disclosure, Scanbuy cannot guarantee its absolute security.

Please consider carefully before disclosing any personal information.

4. Personal Information 

Scanbuy collects personal information that you provide to us.  For example, we collect information when you create an account or a profile, configure your preferences, and when you email, text, call, or otherwise communicate with us. 

The types of personal 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 us). 

Scanbuy may be able to collect location based 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 at any time.

Please consider carefully before disclosing any personal information.

5. Purpose and legitimizing basis of the treatments

Below, we provide details about the purposes of the processing carried out by the Data Processor, the legitimizing bases and the period of conservation of the data.

   a. To answer the questions that the data subject sends to us.

          ▪ Legal basis: Consent of the data subject.

          ▪ Period of conservation: The data shall be kept until the issue raised by the data subject has been resolved and for five (5) years to deal with the formulation, exercise or defence of claims.


b. Provision of the Scanlife service described in the Conditions of Use:

    ▪ Manage the user registration of the interested party through the registration form.

    ▪ Maintain service quality and to perform data matching and understand your needs so    that we can provide you with the highest quality of service

    ▪ Retention period: The personal data provided will be kept for the duration of the contractual relationship with the interested party and for five (5) years to deal with the formulation, exercise or defence of claims.

 ▪ Legal basis: Execution of a contract.


c. Elaboration of profiles on the preferences of the interested party.

    ▪ Legal basis:Legitimate interest of the person responsible.

    ▪ Foreseen consequences: the processing of the data does not foresee any consequences that could have any legal effect or in any other way that could significantly affect the data subject. The service offered is not altered in the event that the user does not consent to such processing.

    ▪ Logic used: an automated procedure is used to process the data, where all the coupons downloaded and redeemed are filtered in order to classify the interested party according to his/her circumstances and preferences (age range, place of purchase, type of products purchased, monthly expenditure in the supermarket or pharmacy, etc).

    ▪ Data retention criteria: data relating to profiling will be retained for a maximum period of one year from the last update. In this sense, after this period without updating your data, the information will be blocked in such a way that it will not be available to companies. Once three years have passed without updating the information, the data will be deleted, guaranteeing full respect for confidentiality, both in processing and in subsequent destruction.


d. Submit personalized promotional information about SCANLIFE services by means of e-mail and notifications in the Apps themselves.

    ▪ Legal basis: express consent of the interested party.

    ▪ We inform you that you may withdraw the consent given at any time, without affecting the legality of the processing carried out previously by the Data Processor.

    ▪ Storage period: The personal data provided by the user will be kept as long as he/she does not withdraw his/her consent.


e. Drawing up of statistics relating your activity to analyze the effectiveness of its website and software applications and make improvements where needed.

    ▪ Retention period: The personal data provided will be kept for the duration of the contractual relationship with the data subject. Once the relationship has ended, the data will be subject to anonymization operations and will be kept by the Data Processor.

    ▪ Legal basis: Execution of a contract. Compatible purpose.


f. Assessment and management of the job application for the selection and contracting of personnel, in order to offer positions that fit your profile.

    ▪ Legal basis: Consent of the interested party.

    ▪ Period of conservation: the personal data will be conserved for a maximum period of one year.


g. Geolocation of the data subject.

    ▪ Legal basis: Consent of the data subject. The data subject may authorise or activate the geolocation permit so that, by means of its location, locate the services and information scanned.

    ▪ Period of conservation: the personal data will be conserved for a maximum period of one year.

6. Obligation to provide data

By marking the corresponding boxes and entering data in the fields marked with an asterisk (*) on the contact form or presented on download forms, the USERS expressly accept, freely and unequivocally, that their data are necessary to attend to their request, on the part of the provider, the inclusion of data in the remaining fields being voluntary. The USER guarantees that the personal data provided to SCANBUY are true and is responsible for communicating any changes to them.

SCANBUY informs that all the data requested through the website marked with an asterisk (*) are compulsory, as they are necessary to provide the USER with an optimum service. In the event that all the data are not provided, it is not guaranteed that the information and services provided will be completely adapted to your needs.

7. Recipients of your data

SCANBUY contracts with third parties in charge of processing the data in order to provide its services. Specifically, the Data Processor has signed agreements with the following service providers:

     ◦ Amazon Web Services EMEA SARL (AWS).

     ◦ The Rocket Science Group (Mailchimp)

     ◦ Microsoft 365

     ◦ Google Analytics, Google Ads, and Firebase

The data you provide may be processed and/or communicated to the companies that belong to our group (whose addresses appear in section 2 of this privacy policy) for the same purposes as those stated above.

In addition, we inform the interested party that their data relating to registration (treatment no. 2) and those relating to the allocation and redemption of coupons may be communicated in an anonymous form (that is, without the data being associated with their identity through the use of encryption techniques on the user ID, providing a different encryption for each recipient of the data) to the following categories of recipients:

     ◦ Advertisers of products, such as CPG companies

     ◦ Manufacturers, brands, and their agencies of the consumer products for which the code was scanned Data analysts, AI experts analyzing behavior

     ◦ We may also share personal information with third parties who complete transactions or perform services on our behalf.  These third parties will be required to treat your information in accordance with our privacy policies.

Scanbuy may also share aggregate level and/or anonymous information with our customers and/or partners for interest-based advertising.  Scanbuy does not share personally identifiable information with our partners, restricting the disclosure to location information, sex/gender, age and other anonymous and/or aggregate level data.

With the exception of the above-mentioned entities, your data will not be communicated to other third parties. If for any reason it is necessary to communicate such data to third parties, you will be informed beforehand and, where appropriate, asked for your consent and the purposes of the communication and the identity of the third party to whom it is to be communicated will be specified.

All of the above, with the exception of those cases in which a legal requirement obliges the communication of such data to a third party.

Scanbuy is not liable for any information collected, used or disclosed by the user’s mobile device manufacturer or service provider. Your internet service provider or mobile carrier network may have access to the communications, such as text messages, phone calls or emails, sent using the mobile device.  For information regarding your service provider’s or carrier’s treatment of your information, please consult their Privacy Policies, which we encourage you to do.  If you decide to use third party applications on your device, any information those applications collect may be sent to third parties and this Policy does not apply.  However, third party applications may have their own Privacy Policies that you should review.

Scanbuy receives information about consumers such as location data and identity and CPG Data from third parties to enable targeted advertising on the website(s) and application(s) that we support. We receive data from:

     ◦ Foursquare

     ◦ Tamoco

     ◦ Irys

     ◦ SMS

     ◦ Lighthouse List

     ◦ DigiCenter

     ◦ Neustar

The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Scanbuy and this Policy does not apply.

8. Rights

Persons who provide us with their data have the following rights in relation to their data:

     ◦ Right of access: Any person has the right to obtain confirmation from the responsible person whether or not personal data concerning him or her is being processed and, if so, the right to access the personal data.

     ◦ Right to rectification: This is the right to obtain the rectification of personal data held by us and concerning you.

     ◦ Right to erasure (The Right to be Forgotten): This is the right to obtain the deletion of your personal data.

Scanbuy cares about your privacy concerns, which may be different for different people. Our goal is to provide you with the information you need to make the most informed choices concerning the information we collect and how it may be used.

When you access the Services, Scanbuy collects your personal information that you provide us, automatically collected information, and retains anonymous and/or anonymized information. Please see Personal Information above to learn more about the types of personal information we may collect. Please see Automatically Collected Information above to learn more about the types of information we may collect automatically. Please see Anonymous & Aggregate Information above to learn more about the anonymous and/or anonymized information that we may retain. If you would like to review what information Scanbuy may have about you, click here. We want to give you the easiest ways to update, amend or delete your information – unless we have 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).

If you would like to exercise your Right to be Forgotten, under Article 17 of the GDPR, click here. Scanbuy is committed to protecting the integrity of your information from accidental or malicious destruction. Because of this, we 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 and required for the Services to function properly. You can stop the collection of information by uninstalling the application following the standard uninstall processes of your mobile device or via the mobile application marketplace or network.

  ◦ Right to restrict processing: This is the right to have your data no longer subject to the corresponding processing operations when one of the following conditions is met:

     ▪ When you have exercised your rights to rectification or objection and the Dara Processor is in the process of determining whether the request is appropriate.

     ▪ If the data processing is unlawful, which implies the deletion of the data, but you do not wish your data to be deleted by the Data Processor.

     ▪ If the data are no longer necessary for processing, which implies deletion of the data, but you wish the Data Processor to limit the processing of the data and to keep them in order to be able to formulate, exercise or defend against claims.

You can exercise this right by sending an e-mail to our address legal@scanbuy.com


    ◦ Right to data portability: This is the right to obtain from the Data Processor, in case of automatic processing of your data, a copy of these data in a structured format, for common use and mechanical reading or that this copy is directly transmitted to the Data Processor you indicate. Please note that this right does not apply to:

     ▪ The data of third parties that you have provided to the person in charge.

     ▪ Data related to you but provided to the Data Processor by third parties.

 

      ◦ Right to object: This is the right to object to the processing of your personal data. With regard to the processing carried out by the Data Processor, you may object to the sending of commercial communications both by yourself and by third parties. To do so, you must log in to your user account, in the “My Account” section, and configure your options. If you wish to obtain more information about your rights, we suggest that you visit the website of the Spanish Data Protection Agency (Click the LINK).

In addition, we inform you about the possibility of filing a complaint with the competent Control Authority, in this case the Spanish Data Protection Agency, especially in the event that you have not been satisfied with the exercise of your rights. You may contact the Spanish Data Protection Agency by telephone on 901 100 099 and 912 663 517 or by visiting them at their address at C/ Jorge Juan, 6. 28001 – Madrid.

9. Automatically Collected Information

Scanbuy collects certain types of non-personally identifiable information 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 the web page.  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 the 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 Services; we may share and allow our third party partners to share this non-identifying information 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.

The foregoing information itself does not personally identify you but could potentially be linked with personal information that you provide us. These statistics allow Scanbuy to analyze the effectiveness of its website and software applications and make improvements where needed. Upon installation on your device, we will provide you with an opportunity to consent to the collection, use and disclosure of such non-personally identifiable information as described in this policy generally and in the Use and Disclosure section in particular. Please note that such non-personally identifiable information may be required in order for the Services to function properly. Please see Data Retention Policy; Managing Your Information; Opt-out Rights below to review your choices regarding your information.

10. Do Not Track

Apple iOS and Google Android devices provide the ability for users to enable a “do not track” setting that disables your advertising identifier. If the “do not track” setting is disabled, we may record when a user installs the App. We may also run targeted advertising on third party applications via our advertising display partners. For users who have enabled the “do not track” setting in iOS or Android, this data will not be collected.

Please note that the “do not track” setting may not be available on all operating systems or versions of ScanLife. The “do not track” settings require iOS 6 or later, or Android 2.3 or later. In order for the “do not track” settings to function on ScanLife, you must have a version of ScanLife installed which is up to date as of the effective date of this Policy.

To enable the “do not track” setting on iOS, visit: http://support.apple.com/kb/HT4228

To enable the “do not track” setting on Android please perform the following steps: (i) Open your ‘Settings’ app; (ii) Locate Privacy; (iii) Select ‘Advanced’; (iv) Select ‘Ads’; (v) Select ‘Opt out of Ads Personalization’; and (vi) When prompted select ‘Ok’.

For additional details on option out of ads personalization for your Google account, visit the following external link: Opt out of seeing personalized ads

Scanbuy may update these instructions periodically as new information becomes available from Apple, Google, and other Operating System manufacturers.

11. Anonymous & Aggregate Information

Scanbuy collects some information on an anonymous basis. Scanbuy may also anonymize some personal information so that it cannot be readily used to personally identify an individual user. Scanbuy obtains aggregate information by combining anonymous information that meet certain criteria into groups. Scanbuy may share aggregate or anonymous information in various formats with our users and partners, and may work with our partners to do research to improve the products and services we provide where needed.

12. Use and Disclosure

In accordance with your choices made upon installation on your device, you agree that Scanbuy may access, preserve, and disclose your information in connection with your use of the Application 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, the filtering of spam), (d) respond to user support requests, or (e) protect the rights, property or safety of Scanbuy, its users, and the public.

Scanbuy may use third party service providers and business partners to perform functions in connection with the Services. Scanbuy may share information about you that they need to perform their functions, but they may not use it for other purposes. IN ACCORDANCE WITH YOUR CHOICES MADE UPON INSTALLATION ON YOUR DEVICE, YOU CONSENT TO THE DISCLOSURE OF INFORMATION FROM YOU AND ABOUT YOU AS DESCRIBED ABOVE AND HEREIN.

Scanbuy works with third parties to collect certain non-identifying information about your interests, including aggregate level and/or anonymous information, to provide targeted advertising and analytics services on our site or within our application, or across other sites and other applications. These entities may use technologies to collect information about your use of our mobile applications, 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-identifying information with other third parties that perform targeted advertising activities across other apps and websites. Please see Data Retention Policy; Managing Your Information; Opt-out Rights below to review your choices regarding your information.

Data collected from a particular device may be used on a different device that is linked to the device on which the data was originally collected. Any choice made by you regarding Scanbuy’s collection of data on one device will be reflected on the other device(s) linked to that device. Please consider carefully before making any choices regarding Scanbuy’s collection of data.

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 also share your information with our affiliates for purposes consistent with this Policy. Our affiliates will be required to maintain that information in accordance with this Policy.

Scanbuy may combine all of the information collected from or about you and use it in the manner described in this Policy. 

Scanbuy may share aggregated and anonymized information relating to users of the Services with affiliated or unaffiliated third parties.

If you have any questions or concerns with respect to this Policy, you may contact us at privacy@scanbuy.com.

13. Data Retention Policy, Managing Your Information, Opt-out Rights

Scanbuy retains automatically collected information as well user provided data.  Please see Transparency and Choice below to learn how you can access your information, and how you can update, amend or delete your information. Please note that some of your information may be required in order for the Services to function properly.

Information collected by Scanbuy in connection with your use of our products and services may be stored and processed in the United States or any other country in which Scanbuy maintains facilities. Accordingly, your use of ScanLife, or any other products or services provided, grants Scanbuy permission to transfer such information to other Scanbuy facilities which may be outside of your country. 

We may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third countries with which we work and which may be located in jurisdictions outside the EEA, Switzerland and the UK that do not have data protection laws or laws that are less stringent compared to those in Europe.

When we transfer Personal Data outside the EEA, Switzerland or the UK, we take the required legal steps to ensure that appropriate security measures are in place to protect your Personal Data. This includes the use of the Standard Contractual Clauses ("SCC") on Controllers and Processors in the Annex to the COMMISSION DECISION of 27 December 2004 amending Decision 2001/497/EC as regards the introduction of an alternative set of standard contractual clauses for the transfer of personal data to third countries.

You can stop the collection of information by ScanLife by uninstalling the application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. Information collected by Scanbuy in connection with your use of our products or services may be held onto after you are no longer a customer.

Scanbuy may also share aggregate level and/or anonymous information with our customers and/or partners.  Scanbuy does not share personally identifiable information with our partners, restricting the disclosure to location information, sex, age and other anonymous and/or aggregate level data. Scanbuy provides an opt-out tool which is cookie based. If you’d like to opt-out of Scanbuy’s use of your aggregate level and/or anonymous information, outside of use that is required for the Services to function properly, please visit the link below and follow the relevant instructions:

To opt-out of Scanbuy’s use of aggregate level and/or anonymous information, as well as any other non-identifying information as described in this Privacy Policy, aside from the primary usage required for the Services to function properly, click here.

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

To opt-out of Oracle’s use of aggregate level and/or anonymous information, visit http://www.bluekai.com/privacypolicy.php or http://www.bluekai.com/consumers.php#optout

You may also opt-out of the collection of aggregate level and/or anonymous information using mechanisms provided by industry groups such as the Network Advertising Initiative (the “NAI”), the Digital Advertising Alliance (the “DAA”) and the European Digital Advertising Alliance (the “eDAA”).

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/

Please note that the opt-out tools discussed above are cookie-based, and only prevent the collection of information pertaining to you on the browser on which they are installed, will only function as described if you 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.

14. Children

Scanbuy’s products and services are intended for adult use only and we do not knowingly solicit data from or market to children under the age of 13.  Scanbuy’s products and services are not intended for children, and we ask that minors not submit any personal information to us.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@scanbuy.com. We will delete such information from our files within a reasonable time.