Privacy Statement

Last updated: April 19, 2019

This Privacy Policy describes how we collect, use, and disclose information obtained via the Scintel.com website, including the country-specific webpages you may be directed to based on your location and the IP address from which you may access our site and this Privacy Policy. This Privacy Policy also applies to information we may collect and process via our social media pages and accounts (Facebook, LinkedIn, YouTube and Twitter) and when you use certain Scintel applications (like Prophesy) and extensions that connect to your Scintel online account.

The Scintel.com website is owned by Scintel Technologies and Scintel Analytics Inc. (hereinafter referred to as “we”, “us”, “Scintel” or the “Company”), located in the United States. If you are located in the European Economic Area (EEA) or Switzerland, the terms of our Privacy Shield Privacy Policy will also apply to you and is incorporated herein by reference.

Please note that in order to use our website, you authorize Scintel to transfer your personal information across national borders and to other countries where Scintel and its partners operate, including the United States. The privacy protections and rights of authorities to access your information in these countries may not be equivalent to those in the jurisdiction where you are located. We will only transfer your personal information to these countries where permitted to do so by law and we will take steps intended to ensure that your personal information continues to receive appropriate protections.

If the content or information that you disclose to us contains the personal information of other individuals, you must be legally permitted to share it with us.

Summary of Key Points

· By using our website (including any Scintel.com subdomains), signing up for Scintel-sponsored events, registering for a Scintel Prophesy account, accessing the Scintel Prophesy administrative console, and/or interact with Scintel-managed social media pages on third party platforms (e.g., Facebook, Twitter, LinkedIn, or YouTube) you agree to the terms of this Privacy Policy, which includes information about the choices you have with respect to how we use and share your data.

· We will obtain your permission before (i) sending you promotional material about Scintel products and services; and (ii) accessing information stored on your device relating to your use of, and engagement with, our website, social media pages and crash reports. You can withdraw your consent for us to engage in these activities at any time. This can be done by opting out using the unsubscribe link found at the bottom of our marketing emails, or by contacting us at ProphesySupport@Scintel.com.

· This policy explains when we process personal information for our legitimate interests. For example, we may use your personal information to send you important information about your account; provide the Scintel products and services you have requested from us; authenticate users who access the Scintel platform and/or sign in to a Scintel account; monitor performance and activity on our systems and networks; and for other purposes described in this Privacy Policy to the extent permitted by law.

· We may also share your contact information with our advertising and sales partners, consistent with your choices.

· We may disclose information to third parties we engage to process data on our behalf, when disclosure may be required in order for us to comply with legal obligations or in certain other situations if required by law.

· We provide interactive features that engage with social media sites, such as Facebook, Twitter, LinkedIn and YouTube. If you use these features, these sites will send us personal information about you.

· We use cookies and other technologies to track the use of our websites and apps. If you are using our Site in a browser, the related information is available in our Cookie Policy.

· We transfer your personal information to the US and other countries, which may be outside the country in which you live. We use the European Commission approved contract clauses and Privacy Shield to help protect your personal information.

What does this privacy policy cover?

This privacy policy describes how we will make use of your information in the context of:

· Scintel.com websites (including sub-domains to which you may be redirected based on your location);

· If you have a Scintel Prophesy account, your use of the Scintel Prophesy platform and certain extensions or applications once you log in to your account;

· Personal information shared with us or that which you make publicly available when interacting with our social media accounts or by visiting our pages on social media sites; however, such sites are not owned, managed or controlled by Scintel. The collection, use, and disclosure of your personal information while visiting these other sites is subject to their respective privacy policies (not Scintel’s) – so please review those policies before disclosing any personal information on those sites; and

· Scintel’s online marketing, sales, and advertising practices.

This privacy policy does not cover the privacy practices of Scintel resellers or other entities that use Scintel product link on their websites. If you are the customer of other third parties who uses the Scintel platform on their website, please refer to the privacy policy on that site for information about how they may use and disclose of your personal data.

If you are a Scintel business customer, you may be subject to additional privacy terms in place of or as a supplement to this privacy policy as part of a license or other commercial agreement in place between you and Scintel.

What personal information does Scintel collect?

When you register on our website or sign up to attend an event or webinar, request information or content from us, or contact us for support, Scintel collects information that identifies you. This information may include:

· Name;

· Company name;

· Email address;

· Username and other login credentials;

· Telephone number;

· Address;

· Country;

· Whether you have provided consent for us to use and/or share your personal information in a specific way and the time and date such consent was given; and

· Information you provide to us through customer support communications.

To help keep our databases current and to provide you with the most relevant content and experiences, we may combine information provided by you with information from third party sources, in accordance with applicable law. For example, the size, industry, and other information about the company you work for (where you have provided company name) will be obtained from sources including professional networking sites, business databases and registries, and other information we are able to obtain from our service providers.

If you register for an event or request information from Scintel and one or more of its partners, your information will be shared with these partners with your consent.

We collect information about how you use our websites, extensions, social media content and our platform. This information may be anonymous, or it may be associated with you. It includes:

· IP address;

· Type of browser and device;

· The Webpage that led you to a Scintel website;

· Search terms entered into a search engine which leads you to a Scintel website;

· How you use and navigate across our website, the Scintel platform, and certain extensions (collected through cookies and similar technologies, or by Scintel servers when you are logged in to the website or platform);

· Analysis of your content (e.g., activity logs, and direct feedback from you); and

· Other data that is necessary in order for us to provide products or services to you, including information sent to us in order for extensions or applications you add to your Scintel deployment to operate.

How does Scintel use my personal information?

Scintel uses the information we collect about you for the following purposes:

· To fulfill a contract, or take steps linked to a contract (such as providing customer support, sending you security or other updates and patches); and facilitating the use of extensions, tools, and apps. This includes:

o Providing you with access to your Scintel administrative console and other Scintel products and services you have purchased from us;

o Verifying your identity;

o Sending you necessary communications (for example, related to payments or expiration of your subscription); and

o Analyzing your use and measuring the effectiveness of our websites, platforms and extensions to better understand how they are being used and improve our customer experience;

o To enhance, improve, modify or create new products and services;

o For determining the effectiveness of our promotional campaigns, so that we can adapt them to the needs and interests of our users;

o Using automated systems to analyze your content using techniques such as machine learning in order to improve our services and the user experience (where your consent is not required);

o Diagnosing problems with our websites, platforms, or network;

o Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission);

o Investigating and responding to any comments or complaints that you may send to us;

o To prevent fraud, misuse and illegal activity our websites, platforms and systems such as to detect and prevent cyberattacks or attempts to commit identity theft; and

o In connection with legal claims, audits, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with a contractual obligation, legal process or litigation).

· Where you give Scintel your consent or when doing so is otherwise consistent with your choices we will:

o Send you information about Scintel products and services, special offers and similar information;

o Place cookies and use similar technologies on our websites, on our apps and in email communications, in accordance with our Cookies Policy and the information available to you when those technologies are used;

o Access crash reports and other information stored on your device relating to your use of, and engagement with, websites and applications;

o On other occasions where we ask you for consent, we will use the information only for the purpose(s) for which you have agreed that it may be used unless we are required to do otherwise by law.

USE OF SERVICES BY MINORS

Our website and Services not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).

Does Scintel share my personal information?

Sharing with third parties

Scintel may also share your personal information with other third parties:

· When you agree to the sharing by disclosing it to others, e.g., you post content on message boards, online chats, blogs, Scintel Forums and our social media pages (please note that any information you post or disclose via these methods will become public and may be available to other users and the general public and we are not responsible for the information collection, use, disclosure or security of these third parties);

· When we are required to provide information in response to a subpoena, court order, or other applicable law or legal process (note that this may include laws or legal obligations imposed by other jurisdictions other than where you are located);

· When we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our systems and networks against attacks, or protect the property and safety of Scintel, our customers and users, or the public; and

· If we merge with or are acquired by another company, sell a Scintel website, app, or business unit, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner.

This privacy policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service that may be accessible via a link on our platform or websites. The inclusion of a link on a Scintel webpage does not imply endorsement of the linked site or service by us or by our affiliates.

Other information: collection and use

To the extent permitted by law, we may use and share aggregated or pseudonymized information that doesn’t specifically identify you (“Other Information”), such as statistical information about how customers use our customer support services, consoles, platforms, websites, and extensions; browser information, device type, demographic information that does not identify you, and data collected from cookies, pixel tags and other technologies that are not linked or dissociated from individual identifiers (like cookie IDs). We use this information to ensure that our websites, platforms and other online services are working correctly. If we are required to treat Other Information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information as detailed in this privacy policy.

Cookies and Pixels

Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on our websites and platforms, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about the use of the services in order to continually improve their design and functionality, understand how they are used, to monitor website performance, and track the effectiveness of our online marketing activities.

Cookies also help us track the success of our online ads by providing information about which ads are displayed to you, whether they were clicked on and where the ad was displayed.

We do not respond to do-not-track signals. We engage in cross-site tracking, which means that we may serve you ads after visiting our site as part of a retargeting campaign.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.

If you do not accept cookies, you may not be able to use some of the features on our websites and some functions may not work correctly. You also may not receive advertising or other offers from us that may be relevant and tailored to your interests. For more information about our cookies and your choices regarding them can be found in our Cookie Policy.

In addition to cookies, we use pixel tags (also known as web beacons and clear GIFs) to, among other things, track user engagement with our online ads and email messages, measure the success of our marketing campaigns and compile statistics about response rates, and understand more about how our online services are used.

Sensitive Information

We ask that you do not send nor disclose to us any sensitive personal information (e.g., social security or other government identification numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our websites, platform, customer support process, or any other means of communication.

Is my personal information secure?

We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective so please be careful when disclosing your personal information to anyone online.

Where does Scintel store my personal information?

Your personal information and files are stored on our servers and the servers of companies we hire to provide services to us. Information about the location of our servers and sub-processors can be found here.

Does Scintel transfer my personal information across national borders?

We may transfer your personal information across national borders to other countries in compliance with applicable laws.

Where Scintel transfers your personal information to a country which is not within the EEA and is not subject to an adequacy decision by the EU Commission, we rely on one or more of the following legal mechanisms: EU-U.S. Privacy Shield, Swiss-U.S. Privacy Shield, European Commission approved Standard Contractual Clauses and your consent in certain circumstances. A copy of the relevant mechanism can be provided for your review upon request, using the contact details provided at the end of this privacy policy. For more information about the certification of Scintel to the EU-U.S. Privacy Shield, please visit our Privacy Shield Privacy Policy. Details about the standard contractual clauses we may also use when we transfer data to third countries are available here.

Your rights as a data subject

Under the law of some countries, you may have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this information to another controller.

In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirements, or where we are using the information for direct marketing).

These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping (such as fraud prevention purposes).

To exercise any of these, you can get in touch with us – or our data protection officer – using the details set out below.

If you have unresolved concerns, you have the right to report them to an EU or other data protection authority where you live, work or where you believe a potential violation may have occurred.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent to process your personal information, you will always be able to withdraw that consent, although we may have other legal grounds to continue processing your information, such as those set out above. In some cases, we are able to send you marketing information without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing communications or the profiling, we carry out for marketing purposes at any time by:

updating your preferences in your Scintel account profile;

updating your preferences in your specific website or app accounts;

clicking the unsubscribe link at the bottom of our marketing emails; or

contacting us using the details provided at the end of this privacy policy.

Updates, corrections, restrictions, and copies

If you would like to request to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by emailing privacy@Scintel.com. We will respond to your request consistent with applicable law.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we will only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual non-identifiable information that will remain in our databases and other records which will not be removed.

Data Retention

We will retain your personal information for as long as needed in light of the purpose(s) for which it was provided. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the services we agreed to you; (ii) when we have legal obligation to which we are subject; or (iii) as advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Changes to this policy

Occasionally, we may change this privacy policy to allow us to use or share your personal information in a different way. If we do, the links to the policy on our websites (which are generally found in the footer of the website) will indicate that the policy has been changed. For new users, the change will become effective upon posting. For existing users, if the change is significant, it will become effective 30 days after posting. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact

If you have a privacy question, concern, or request, please send an email to ProphesySupport@Scintel.com.

You may also contact us at Scintel Technologies 6340 Sugarloaf Parkway, Suite 200, Duluth, GA 30097, USA with any questions about this Privacy Policy.