Last updated: August 15, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of
Your information when You use the Service and tells You about Your privacy rights and how the law
protects You.
** We use Your Personal data to provide and improve the Service.
By using the Service, You agree to the collection and use of
information in accordance with this Privacy Policy. **
Table of Contents
Privacy Policy ................................................................................................................................1
1. Interpretation and Definitions ......................................................................................... 4
1.1. Interpretation ........................................................................................................................................................4
1.2. Definitions ...............................................................................................................................................................4
2. Collecting and Using Your Personal Data ...................................................................... 6
2.1. Types of Data Collected......................................................................................................................................6
2.1.1. Personal Data ....................................................................................................................................................6
2.1.2. Usage Data ..........................................................................................................................................................6
2.1.3. Information from Third-Party Social Media Services......................................................................6
2.1.4. Tracking Technologies and Cookies........................................................................................................7
2.2. Use of Your Personal Data ................................................................................................................................8
2.3. Retention of Your Personal Data ...................................................................................................................9
2.4. Transfer of Your Personal Data................................................................................................................... 10
2.5. Delete Your Personal Data............................................................................................................................. 10
2.6. Disclosure of Your Personal Data............................................................................................................... 10
2.6.1. Business Transactions................................................................................................................................ 10
2.6.2. Law enforcement.......................................................................................................................................... 10
2.6.3. Other legal requirements .......................................................................................................................... 10
2.7. Security of Your Personal Data.................................................................................................................... 11
3. Detailed Information on the Processing of Your Personal Data..........................11
3.1. Analytics ................................................................................................................................................................ 11
3.2. Email Marketing................................................................................................................................................. 11
3.3. Payments............................................................................................................................................................... 11
3.4. Behavioral Remarketing................................................................................................................................. 12
3.5. Usage, Performance and Miscellaneous .................................................................................................. 13
4. Swiss National Federal Act on Data Privacy (nFADP) .............................................14
4.1. Legal Basis for Processing Personal Data under nFADP .................................................................. 14
4.2. Your Rights under nFADP.............................................................................................................................. 14
4.3. Exercising of Your nFADP Data Protection Rights.............................................................................. 15
4.4. Notable Procedures related to Swiss Market Place............................................................................ 15
5. GDPR Privacy ........................................................................................................................15
5.1. Legal Basis for Processing Personal Data under GDPR..................................................................... 15
5.2. Your Rights under the GDPR ........................................................................................................................ 16
5.3. Exercising of Your GDPR Data Protection Rights ................................................................................ 16
6. Facebook Fan Page..............................................................................................................17
6.1. Data Controller for the Facebook Fan Page ........................................................................................... 17
6.2. Facebook Insights.............................................................................................................................................. 17
7. CCPA/CPRA Privacy Notice (California Privacy Rights) .........................................17
7.1. Categories of Personal Information Collected ...................................................................................... 17
7.1.1. Category A: Identifiers................................................................................................................................ 18
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7.1.2. Category B: Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)). ...................................................................................................................... 18
7.1.3. Category C: Protected classification characteristics under California or federal law..... 18
7.1.4. Category D: Commercial information. ................................................................................................. 18
7.1.5. Category E: Biometric information....................................................................................................... 18
7.1.6. Category F: Internet or other similar network activity................................................................ 18
7.1.7. Category G: Geolocation data. ................................................................................................................. 18
7.1.8. Category H: Sensory data. ......................................................................................................................... 19
7.1.9. Category I: Professional or employment-related information. ................................................ 19
7.1.10. Category J: Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))............................................................................... 19
7.1.11. Category K: Inferences drawn from other personal information....................................... 19
7.1.12. Category L: Sensitive personal information................................................................................. 19
7.2. Sources of Personal Information ................................................................................................................ 19
7.3. Use of Personal Information......................................................................................................................... 20
7.4. Disclosure of Personal Information........................................................................................................... 20
7.5. Share of Personal Information..................................................................................................................... 21
7.6. Sale of Personal Information........................................................................................................................ 21
7.7. Sale of Personal Information of Minors Under 16 Years of Age.................................................... 21
7.8. Your Rights under the CCPA/CPRA........................................................................................................... 22
7.9. Exercising Your CCPA/CPRA Data Protection Rights ........................................................................ 23
7.10. Do Not Sell My Personal Information .................................................................................................. 24
7.10.1. Website ........................................................................................................................................................ 25
7.10.2. Mobile Devices .......................................................................................................................................... 25
7.11. Limit the Use or Disclosure of My Sensitive Personal Information........................................ 25
8. "Do Not Track" Policy as Required by California Online Privacy Protection Act
(CalOPPA)...........................................................................................................................................25
9. Your California Privacy Rights (California's Shine the Light law) ......................26
10. California Privacy Rights for Minor Users (California Business and
Professions Code Section 22581) ..............................................................................................26
11. Children's Privacy ...............................................................................................................26
12. Links to Other Websites ....................................................................................................26
13. Changes to this Privacy Policy.........................................................................................26
14. Contact Us...............................................................................................................................27
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1. Interpretation and Definitions
1.1. Interpretation
The words of which the initial letter is capitalized have meanings defined under the
following conditions. The following definitions shall have the same meaning regardless of
whether they appear in singular or in plural.
1.2. Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our
Service.
Affiliate means an entity that controls, is controlled by or is under common control with a
party, where "control" means ownership of 50% or more of the shares, equity interest or
other securities entitled to vote for election of directors or other managing authority.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that
collects Consumers' personal information and determines the purposes and means of the
processing of Consumers' personal information, or on behalf of which such information is
collected and that alone, or jointly with others, determines the purposes and means of the
processing of consumers' personal information, that does business in the State of California.
CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended
by the California Privacy Rights Act of 2020 (the "CPRA").
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement)
refers to ScoutSync LLC, Max-Högger-Strasse 6, 8048 Zurich, Switzerland.
For the purpose of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California
resident. A resident, as defined in the law, includes (1) every individual who is in the USA
for other than a temporary or transitory purpose, and (2) every individual who is domiciled
in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on Your computer, mobile device or any other device
by a website, containing the details of Your browsing history on that website among its
many uses.
Country refers to: Switzerland
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers
to the Company as the legal person which alone or jointly with others determines the
purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cellphone or a
digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in
particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their
online activities across websites.
Facebook Fan Page is a public profile named ScoutSync specifically created by the
Company on the Facebook social network, accessible from
https://www.facebook.com/scoutsync
GDPR refers to EU General Data Protection Regulation.
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such as a
name, an identification number, location data, online identifier or to one or more factors
specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that identifies,
relates to, describes or is capable of being associated with, or could reasonably be linked,
directly or indirectly, with You.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of
the Company. It refers to third-party companies or individuals employed by the Company to
facilitate the Service, to provide the Service on behalf of the Company, to perform services
related to the Service or to assist the Company in analyzing how the Service is used.
For the purpose of the GDPR, Service Providers are considered Data Processors.
nFADP refers to the Swiss National Federal Act on Data Privacy
Within nFADP the supervisory authority is the Federal Data Protection and Transparency
Commissioner (FDPIC).
Third-party Social Media Service refers to any website or any social network website
through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service
or from the Service infrastructure itself (for example, the duration of a page visit).
Website(s) refers to ScoutSync, accessible from www.scoutsync.com and or
www.scoutsync.online
You means the individual accessing or using the Service, or the company, or other legal
entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the
individual using the Service.
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2. Collecting and Using Your Personal Data
2.1. Types of Data Collected
2.1.1. Personal Data
While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You. Personally
identifiable information may include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Bank account information in order to pay for products and/or services within
the Service
• Usage Data
When You pay for a product and/or a service via bank transfer, We may ask You to
provide information to facilitate this transaction and to verify Your identity. Such
information may include, without limitation:
• Date of birth
• Passport or National ID card
• Bank card statement
• Other information linking You to an address
2.1.2. Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address
(e.g. IP address), browser type, browser version, the pages of our Service that You
visit, the time and date of Your visit, the time spent on those pages, unique device
identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile device
You use, Your mobile device unique ID, the IP address of Your mobile device, Your
mobile operating system, the type of mobile Internet browser You use, unique
device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.
2.1.3. Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through
the following Third-party Social Media Services:
• Google
• Facebook
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• Instagram
• Twitter
• LinkedIn
If You decide to register through or otherwise grant us access to a Third-Party Social
Media Service, We may collect Personal data that is already associated with Your
Third-Party Social Media Service's account, such as Your name, Your email address,
Your activities or Your contact list associated with that account.
You may also have the option of sharing additional information with the Company
through Your Third-Party Social Media Service's account. If You choose to provide
such information and Personal Data, during registration or otherwise, You are
giving the Company permission to use, share, and store it in a manner consistent
with this Privacy Policy.
2.1.4. Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our
Service and store certain information. Tracking technologies used are beacons, tags,
and scripts to collect and track information and to improve and analyze Our Service.
The technologies We use may include:
• Cookies or Browser Cookies. A cookie is a small file placed on Your Device.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie
is being sent. However, if You do not accept Cookies, You may not be able to use
some parts of our Service. Unless you have adjusted Your browser setting so
that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel tags,
and single-pixel gifs) that permit the Company, for example, to count users who
have visited those pages or opened an email and for other related website
statistics (for example, recording the popularity of a certain section and
verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your
personal computer or mobile device when You go offline, while Session Cookies are
deleted as soon as You close Your web browser. You can learn more about cookies
on TermsFeed website article.
We use both Session and Persistent Cookies for the purposes set out below:
• Necessary / Essential Cookies
o Type: Session Cookies
o Administered by: Us
o Purpose: These Cookies are essential to provide You with services
available through the Website and to enable You to use some of its
features. They help to authenticate users and prevent fraudulent use of
user accounts. Without these Cookies, the services that You have asked
for cannot be provided, and We only use these Cookies to provide You
with those services.
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• Cookies Policy / Notice Acceptance Cookies
o Type: Persistent Cookies
o Administered by: Us
o Purpose: These Cookies identify if users have accepted the use of
cookies on the Website.
• Functionality Cookies
o Type: Persistent Cookies
o Administered by: Us
o Purpose: These Cookies allow us to remember choices You make when
You use the Website, such as remembering your login details or
language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter
your preferences every time You use the Website.
• Tracking and Performance Cookies
o Type: Persistent Cookies
o Administered by: Third-Parties
o Purpose: These Cookies are used to track information about traffic to
the Website and how users use the Website. The information gathered
via these Cookies may directly or indirectly identify you as an
individual visitor. This is because the information collected is typically
linked to a pseudonymous identifier associated with the device you use
to access the Website. We may also use these Cookies to test new pages,
features or new functionality of the Website to see how our users react
to them.
For more information about the cookies, we use and your choices regarding
cookies, please visit our Cookies Policy or the Cookies section of our Privacy
Policy.
2.2. Use of Your Personal Data
The Company may use Personal Data for the following purposes:
• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the Service
that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of any
other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms of electronic communication, such as a mobile application's push notifications
regarding updates or informative communications related to the functionalities,
products or contracted services, including the security updates, when necessary or
reasonable for their implementation To provide You: with news, special offers and general information about other goods,
services and events which we offer that are similar to those that you have already
purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• To deliver targeted advertising to You: We may use Your information to develop and
display content and advertising (and work with third-party vendors who do so)
tailored to Your interests and/or location and to measure its effectiveness.
• For business transfers: We may use Your information to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer
of some or all of Our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which Personal Data held by Us about our Service
users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our promotional
campaigns and to evaluate and improve our Service, products, services, marketing and
your experience.
We may share Your personal information in the following situations:
• With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to advertise on third party
websites to You after You visited our Service, for payment processing, to contact You.
• For business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we
will require those affiliates to honor this Privacy Policy. Affiliates include Our parent
company and any other subsidiaries, joint venture partners or other companies that We
control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners
to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the
public areas with other users, such information may be viewed by all users and may be
publicly distributed outside. If You interact with other users or register through a
Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service
may see Your name, profile, pictures and description of Your activity. Similarly, other
users will be able to view descriptions of Your activity, communicate with You and view
Your profile.
• With Your consent: We may disclose Your personal information for any other purpose
with Your consent.
2.3. Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the
purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the
extent necessary to comply with our legal obligations (for example, if we are required to
retain your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
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The Company will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used to strengthen
the security or to improve the functionality of Our Service, or We are legally obligated to
retain this data for longer time periods.
2.4. Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices
and in any other places where the parties involved in the processing are located. It means
that this information may be transferred to — and maintained on — computers located
outside of Your state, province, country or other governmental jurisdiction where the data
protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information
represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated
securely and in accordance with this Privacy Policy and no transfer of Your Personal Data
will take place to an organization or a country unless there are adequate controls in place
including the security of Your data and other personal information.
2.5. Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We
have collected about You.
Our Service may give You the ability to delete certain information about You from within
the Service.
You may update, amend, or delete Your information at any time by signing in to Your
Account, if you have one, and visiting the account settings section that allows you to manage
Your personal information. You may also contact Us to request access to, correct, or delete
any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal
obligation or lawful basis to do so.
2.6. Disclosure of Your Personal Data
2.6.1. Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data
may be transferred. We will provide notice before Your Personal Data is transferred
and becomes subject to a different Privacy Policy.
2.6.2. Law enforcement
Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by public
authorities (e.g. a court or a government agency).
2.6.3. Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:
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• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
2.7. Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While We
strive to use commercially acceptable means to protect Your Personal Data, We cannot
guarantee its absolute security.
3. Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors
collect, store, use, process and transfer information about Your activity on Our Service in
accordance with their Privacy Policies.
3.1. Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
• Google Analytics:
o Google Analytics is a web analytics service offered by Google that tracks and
reports website traffic. Google uses the data collected to track and monitor the use
of our Service. This data is shared with other Google services. Google may use the
collected data to contextualize and personalize the ads of its own advertising
network.
o You can opt-out of having made your activity on the Service available to Google
Analytics by installing the Google Analytics opt-out browser add-on. The add-on
prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing
information with Google Analytics about visits activity.
o For more information on the privacy practices of Google, please visit the Google
Privacy & Terms web page: https://policies.google.com/privacy
3.2. Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional
materials and other information that may be of interest to You. You may opt-out of
receiving any, or all, of these communications from Us by following the unsubscribe link or
instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
• Wix
o Their Privacy Policy can be viewed at https://www.wix.com/about/privacy
3.3. Payments
We may provide paid products and/or services within the Service. In that case, we may use
third-party services for payment processing (e.g. payment processors).
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We will not store or collect Your payment card details. That information is provided directly
to Our third-party payment processors whose use of Your personal information is governed
by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS
as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure
handling of payment information.
• Stripe
o Their Privacy Policy can be viewed at https://stripe.com/us/privacy
• PayPal
o Their Privacy Policy can be viewed at
https://www.paypal.com/webapps/mpp/ua/privacy-full
• Twint
o Their Privacy Policy can be viewed at https://www.twint.ch/en/data-privacy/
When You use Our Service to pay a product and/or service via bank transfer, We may ask
You to provide information to facilitate this transaction and to verify Your identity.
3.4. Behavioral Remarketing
The Company uses remarketing services to advertise to You after You accessed or visited
our Service. We and Our third-party vendors use cookies and non-cookie technologies to
help Us recognize Your Device and understand how You use our Service so that We can
improve our Service to reflect Your interests and serve You advertisements that are likely
to be of more interest to You.
These third-party vendors collect, store, use, process and transfer information about Your
activity on Our Service in accordance with their Privacy Policies and to enable Us to:
• Measure and analyze traffic and browsing activity on Our Service
• Show advertisements for our products and/or services to You on third-party websites
or apps
• Measure and analyze the performance of Our advertising campaigns
Some of these third-party vendors may use non-cookie technologies that may not be
impacted by browser settings that block cookies. Your browser may not permit You to block
such technologies. You can use the following third-party tools to decline the collection and
use of information for the purpose of serving You interest-based advertising:
• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You may opt-out of all personalized advertising by enabling privacy features on Your
mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization
(Android). See Your mobile device Help system for more information.
We may share information, such as hashed email addresses (if available) or other online
identifiers collected on Our Service with these third-party vendors. This allows Our thirdparty vendors to recognize and deliver You ads across devices and browsers. To read more