CSCONNECT (together with its subsidiaries, affiliates, officers and directors, as applicable (each individually, or collectively “SmartTag LLC.”, “Csconnect.com”, “Company”, “we” or “us”) is a global retail-tech company that provides consumer packaged goods brands (“Business Partners”) with an advertising platform for for the purpose of delivering advertising to individuals (“user(s)”) who scan QR code, tap NFC tag, download, use or otherwise interact with an app, landing pages or our services (“Digital Assets”), as defined below (collectively, “ Service(s)“).
If you are a resident of any member state of the EU, EEA or UK, this section applies to you.
As required under GDPR, the lawful basis for our data collection and processing is as follows:
CSCONNECT.io acts as a Processor of certain Personal Data, as defined under the GDPR, such as the data processed from our users using our Business Partners’ Digital Assets. CSCONNECT.io is also a Controller of certain Personal Data, such as our Business Partner’s registration data, or if individuals contact us via our Site.
PRIVACY PRACTICES FOR THE OUR BUSINESS PARTNERS’ DIGITAL ASSETS
Information Collect Through The Digital Assets
Through the Digital Assets, we may (but do not necessarily, or always) collect a variety of information about the users, including:
We may also use third-party services, such as Google Analytics, that gather information such as user IP address, browser type, device type, and the times of your visit.
We may combine and merge the various types of information collected from the Business Partners’ Digital Assets, and may also enhance it (or permit our Business Partners to enhance it) with information collected from third parties. We refer to all of the above information as the “Service Information.”
How We Use the Information Collected Through the Digital Assets
We use the Service Information to provide a variety of services to our Business Partners related to advertising and marketing. This includes the use of the Service Information for purposes such as:
How We Share Information We Collect Through the Digital Assets
Generally, we share the Service Information with our Business Partners in order to provide Digital Assets to the users. For example, we share the Service Information with:
We may also share Service Information with third parties:
User Opt-out Choices
Our Business Partners may provide ways for users to opt-out from, or limit their collection of, certain information from and about users. Please, refer to the privacy policies of a specific brand to learn more about their privacy practices.
PRIVACY PRACTICES FOR THE CSCONNECT WEBSITES
Information We Collect Through the CSCONNECT Websites
The CSCONNECT Websites provide information regarding CSCONNECT and our products and services. Through the CSCONNECT Websites, we collect the information you voluntarily disclose to us, and we may also obtain automatically-collected information.
When registering for an account, expressing an interest in obtaining additional information about CSCONNECT or our products and services, or otherwise contacting us through the CSCONNECT Websites, we collect the information you voluntarily disclose to us, such as your name, mailing address, email address, telephone number, credit card number, and other billing information. You may also provide us with certain information about your business or other individuals.
We may also use third-party services, such as Google Analytics, that gather information such as your IP address, browser type, the web page from which you came to the CSCONNECT Websites, and the times of your visit.
How We Use Information We Collect Through the CSCONNECT Websites
In addition to the uses described elsewhere in this Policy, we use the information we collect through the CSCONNECT Websites (alone or in combination) to provide, market, improve, and operate the CSCONNECT Websites, CSCONNECT Platform, and any other products or services we have or may develop. This includes the use of the information to:
How We Share Information We Collect Through the CSCONNECT Websites
With respect to aggregated or de-identified information, we may share such information without restriction.
DATA ACCESS AND RETENTION
Generally speaking, we retain the information collected from the CSCONNECT Websites and CSCONNECT Platform for as long as necessary to achieve our objectives as detailed in this Policy, and to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you are a resident of the European Union, you may obtain a copy of the information we have about you by contacting us at [ need this email: firstname.lastname@example.org]. Please be advised that, due to the manner in which we collect information, we will only be able to provide you with such information if we can determine that the information is identifiable to you. Under extenuating circumstances, we reserve the right to charge a fee for providing you with such information, and that fee will be based on the costs and fees we incur to fulfill your request.
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect the information from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee the absolute security of your information.
To assist with data security, you understand that YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF ANY ACCOUNT CREDENTIALS THAT CAN BE USED TO ACCESS ANY ACCOUNT WITH CSCONNECT.IO. ANY ACTIONS TAKEN USING YOUR ACCOUNT CREDENTIALS ARE YOUR SOLE RESPONSIBILITY.
THIRD-PARTY WEBSITES AND APPS
This Policy only applies to the CSCONNECT Websites and the CSCONNECT Platform. We are not responsible for the privacy practices or disclosures of websites, developers, or apps that access or use the CSCONNECT Websites or CSCONNECT Platform. Likewise, when you access the CSCONNECT Websites, you may be directed to other websites that are also beyond our control. We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, and the industry tools that we have referenced in this Policy.
Users From Outside The United States
The CSCONNECT Websites and CSCONNECT Platform are provided, supported, and hosted in the United States, and their operation is governed by United States law. If you are using the CSCONNECT Websites or CSCONNECT Platform from outside the United States, be aware that your Information may be transferred to, stored, and processed in the United States and other countries where our facilities are located. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the CSCONNECT Websites or CSCONNECT Platform, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share your information as described in this Policy.
Users residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, these additional terms and conditions apply to you.
Certain data sharing practices we use may be qualified as “data selling” according to the CCPA. In such cases, you will have the right to opt-out via the settings in CSCONNECT Websites, CSCONNECT Platform, and our Business Partners’ Digital Assets. In which case, where you opt-out from data selling, we will receive your opt-out request either directly or from our Business Partner to further execute as required by the CCPA.
(b) We provide the following additional disclosures related to the collection, use, and disclosure of personal information under the CCPA:
Categories of Third Parties with Whom We Share Information. We may share your personal information with third parties as described in the “How We Share Information We Collect Through the Digital Assets” and “How We Share Information We Collect Through the CSCONNECT Websites” sections of this Policy.
Your Consumer Rights. If you reside in California, you have the right to request access to the specific pieces of personal information we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting personal information, the categories of third parties with whom we share your personal information, and the categories of personal information we have disclosed about you in the preceding 12 months. As a California consumer, you also have the right to (i) request deletion of your personal information (subject to certain exceptions), (ii) opt-out of sales of personal information (where and in case existed), and (iii) receive equal service and price and not be discriminated against even if you exercise any of your other CCPA rights.
California consumers may make requests to exercise their rights by using the following methods:
Note that in order to fulfill your request, we may need you to provide certain information to verify your identity. You can also designate an authorized agent to exercise these rights on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA.
Children under CCPA
Our Services are designed for adults, not children under the age of 16. As such, we do not intend to collect personal information from children under the age of 16, and our Services and Business Partners’ Digital Assets are not designed to manage such information. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
We may occasionally update this Policy to reflect changes to our privacy practices. The amended Policy will be displayed on the CSCONNECT Websites. Please check our Policy regularly to ensure you have read the latest version and to stay informed of our privacy practices. Your continued access to and use of the CSCONNECT Websites and CSCONNECT Platform constitute your acknowledgment of this Policy and any updates.
If you have any questions regarding this Policy, please contact us at firstname.lastname@example.org.