HOW SCS COLLECTS AND USES PERSONAL DATA
The personal data we collect depends on how you interact with us, the Services you use, and the choices you make.
We collect information about you from different sources and in various ways when you use our Website and Services, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.
DATA YOU PROVIDE DIRECTLY
When you access and use this Website: SCS collects personal data that you choose to provide to us, for example, on our “Request a Demo” (or similar) online form, apply for a job under careers, or if you register for an SCS webinar. Personal data may include:
Contact information, such as name, email address, job title, company name, postal address, phone number or contact preferences.
Professional information, such as your company name and job title.
Communications, including anything you voluntarily include in a free text or message box. If you contact SCS, we will keep a record of our correspondence.
When you access and use the Services: SCS collects information you provide directly to us. For example, when setting up new users, we may collect:
Contact information, such as name, email address, username, and phone numbers.
Professional information such as job titles, company name, transactional information (including Services purchased).
Content and files provided to us or uploaded to our systems in connection with the Services.
DATA SCS AUTOMATICALLY COLLECTS
When you access and use the Website and Services: When you visit the Website or access and use the Services, SCS collects certain information automatically, such as:
Identifiers and device information, such as your device’s Internet Protocol (IP) address, device identifiers (such as MAC address), device type and operating system, and browser. We may utilize automated tools and files such as “cookies.” As further described in the Cookies and Similar Technologies section below, our Website and Services store and retrieve cookie identifiers, mobile IDs, and other data. If you restrict our ability to store and retrieve this information, your ability to access and use all or part of the Website may be limited or disabled completely. Please see Cookies section below to learn more.
Usage data, such as referring website, what pages your device visited, and the time that your device visited our Website and for what duration.
DATA SCS GENERATES OR INFERS
When you use the Website: We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your city, state, and country location based on your IP address.
When you use the Services: The Services automatically generates insights based on data you provide to us. SCS’s treatment of such data and insights is addressed in our customer agreements.
DATA SCS COLLECTS FROM THIRD PARTY SOURCES
We also obtain information from third parties. These third-party sources and the categories of personal data we obtain from these third parties include, for example:
Data brokers and aggregators from which we collect data to supplement our own data. This may include contact information, professional information demographic information, identifiers and device information, geolocation data, usage data, and inferences.
Third party partners, including platforms, applications, and services (including social networks you choose to connect or interact with our or through our Services). This may include contact information, professional information demographic information, identifiers and device information, geolocation data, usage data, and inferences.
Co-Branding or event partners with whom we offer co-branded services or engage in joint marketing activities. This may include contact information, professional information demographic information, identifiers and device information, geolocation information, and inferences.
Service providers that collect or provide data in connection with work they do on our behalf. This may include contact information, professional information demographic information, payment information, identifiers and device information, geolocation data, usage data, and inferences.
Publicly available sources, such as open government databases. We may collect contact information, professional information demographic information, and inferences.
HOW SCS USES & DISCLOSES YOUR PERSONAL DATA
When you use the Website and Services: SCS uses your personal data for the following purposes:
Website and Service Delivery and Personalization: we may use your contact information, professional information, identifiers and device information, and usage data to provide you with access to the Website and Services, perform analytics and monitoring, and to provide customized content on the Website that may be of interest to you.
Business Operations: we may use your contact information, professional information, identifiers and device information, usage data, content and files, and inferred data to operate our business, such as recruiting and hiring, billing, accounting, improving our internal operations, securing our systems, and detecting fraudulent and illegal activity.
Product Improvement, Development and Research: we may use your contact information, identifiers and device information, usage data, and inferences to improve our Website and Services, develop new services or features, and conduct research.
Authentication: Contact information and identifiers and device information is used to authorize access the Website and Services.
Communications and Customer Support: we may use your contact information to communicate with you when requested or as reasonably necessary to provide the Services.
OUR SHARING OF PERSONAL DATA
We share personal data with your consent or as necessary to complete your transactions or provide you with access to the Website and Services you have requested or authorized. In addition, we share the categories of personal data described above with:
Vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions.
Parties engaged in a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets.
We will also access, transfer, disclose, and preserve personal data when we believe that doing so is necessary to:
comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
operate and maintain the security of our Website and Services, including to prevent or stop an attack on our computer systems or networks; or
protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.
Third party analytics and advertising companies also collect personal data through our Website and Services including, transaction details, account information, marketing and communications data, demographic information, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement.
Finally, we may share de-identified information in accordance with applicable law.
Please note that some of our Services may include references or links to products provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or consent to our sharing personal data with them, that data is governed by their privacy statements.
CHOICE AND CONTROL OF PERSONAL DATA
When you use the Website: SCS may make available chat rooms, forums, message boards, and other interactive features. You should be aware that when you voluntarily disclose personal information (e.g. user name, e-mail address) via forums, postings, profiles or other areas of the Website, that information, along with any substantive information disclosed in your communication, can be collected, correlated and used by third parties and may result in unsolicited messages from other posters or third parties. Such activities are beyond the control of SCS. Please do not post any personal data on the Website or in other areas that you expect to keep private.
If you would like to view, correct, delete, or export personal data that you have submitted through the Websites, please contact firstname.lastname@example.org with your request.
Communications preferences. You can choose whether to receive promotional communications from us by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message or contacting us at email@example.com with your request. These choices do not apply to mandatory service communications that are part of our Services, or to surveys or other informational communications that may have their own unsubscribe method.
Choices for Cookies and Similar Technologies. See the Cookies & Similar Technologies section for choices about cookies and other analytics and advertising controls.
COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small text files placed on your device to store data that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.
Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third-party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.
We, and our analytics and advertising partners, use these technologies on our Website and as part of our Services to collect personal data (such as the cookies stored on your browser or the IP address of your device) when you visit our Website or access and use our Services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our Website and Services perform, track your interaction with the Website or Services, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for these purposes.
The third-party analytics and advertising provider we use on our websites is:
To learn about their privacy practices and how to opt-out from their use of cookie data for targeted advertising purposes, click on the links above.
You may also contact the associations below, which provide a simple way to opt out of analytics and ad targeting, which you can access at:
United States: NAI (http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/)
Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/)
Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/)
Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
Email web beacons. Most email clients have settings which allow you prevent the automatic downloading of images, which will disable web beacons in the email messages you read.
Do Not Track. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
NOTICE TO END USER
If you use an email address provided by an organization you are affiliated with, such as an employer, to access Services, that organization can:
Control and administer your Services account; and
Access and process your data, including the contents of your communications and files, associated with your Services accounts.
If you lose access to your organization (in event of change of employment, for example), you will lose access to Services. SCS Services are intended for use by organizations. If your organization provides you access to Services your use of the Services is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. SCS is not responsible for the privacy or security practices of our customers with respect to such data described above, which may differ from those set forth in this privacy statement.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
You can request access to, and rectification or erasure of, personal data;
If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, contact us at privacy@SCSteam.com. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
OTHER IMPORTANT PRIVACY INFORMATION
SCS is committed to protecting the security of your personal data. We use reasonable technical and organizational measures (TOMs) to help protect your personal data from unauthorized access, use, disclosure, alteration or destruction. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Please note that SCS cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts
SCS retains personal data for as long as necessary to provide the Services and Website and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, the context of our interactions with you or your use of Services and Website, actual retention periods may vary.
COLLECTION OF INFORMATION FROM CHILDREN
We do not knowingly collect personally identifiable information relating to children. In the event that we learn that we have collected personally identifiable information from anyone under 16 years of age without prior parental consent, we will take steps to promptly delete such information. By providing your personal data to SCS, through the Website, you represent that you are 16 years of age or older.
LOCATION OF PERSONAL DATA
Location of Processing European Personal Data. We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
By providing your personal data you consent to:
The transfer of your personal data to the United States as indicated above.
HOW TO CONTACT US
If you have any questions about our privacy practices for SCS or our data protection officier, please feel free to contact us at:
Strong Cyber Solutions, LLC
7416 Willowbrook Road
Fairfax Station, VA 22039