Scrimmage PlayBook Platform Privacy Notice

Effective on: August 18, 2015

Scope of this Notice

This Notice addresses data subjects whose personal identifying information (“PII”) Access Marketing & Communications LLC, dba Scrimmage (“us”, “we,” or “Scrimmage”) may receive from one of our customers, suppliers, or other business partners. This Notice does not apply to employees of Scrimmage, or the data that we receive directly through Scrimmage’s publicly accessible websites.

Confidentiality

Our customers use our hosted technology platform to store data that they control (“Platform Data”) at their own discretion. In this instance, we act only as a storage and service provider, without any interest or knowledge about what is being stored, and shall only access such Platform Data at our customer’s request in connection with customer support or account administration matters, or as may be required by law. Except as described in this Notice, Scrimmage holds Platform Data in confidence.

Categories of PII

Since Platform Data covered by this Notice is by definition sent to us by another company, the categories of data sent and the purposes of use often depend on such other company, with whom the data subject typically has a closer employment or business relationship (and which, therefore, can provide additional information on categories of data shared with us).

Purposes of Use

We collect and use PII for the purposes of providing services to our customers, processing PII on behalf of customers, communicating with corporate business partners about business matters, providing information on our services, and conducting related tasks for legitimate business purposes.

Disclosure

We share Platform Data with our agents and contractors, who process such Platform Data on behalf of Scrimmage. We also share Platform Data with other third parties for the purposes for which we receive the Platform Data (e.g., performance of contractual obligations and rights), and we may also disclose Platform Data where we are legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law or the US-EU Safe Harbor Principles, and we have a legitimate business interest in such disclosure.

Data subjects may send an email to privacy@wescrimmage.com to opt out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for us to provide the requested service(s) to our customer(s).

Data Integrity & Security

Scrimmage employs technical, administrative, and physical measures that are reasonably designed to help protect PII that we process from loss, unauthorized access, disclosure, alteration, or destruction.

Access & Review

If you are a data subject about whom we hold PII, you may request access to, and the opportunity to update, correct, or delete, such PII. To submit such requests or raise any other questions, please contact the business that provided your PII to us. You can also contact us at privacy@wescrimmage.com. We reserve the right to take appropriate steps to authenticate an applicant's identity, to charge a reasonable fee before providing access and to deny requests, except as required by the Safe Harbor Principles.

Contact & Dispute Resolution Process

If you have questions about this Notice, please contact us at:

Attn: Derek Lundsten
Chief Executive Officer
Access Marketing & Communications LLC, dba Scrimmage
60 South 6th Street Suite 2800
Minneapolis, MN 55402
USA

Or you may contact us at privacy@wescrimmage.com. We will promptly investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Notice. If you are not satisfied with our response, or if contacting us does not resolve your complaint, you can contact VeraSafe here: https://www.verasafe.com/dispute-submission. VeraSafe has been appointed as our independent recourse mechanism for Safe Harbor disputes, and we have agreed to participate in the VeraSafe Safe Harbor Dispute Resolution Procedure.

VeraSafe is a trademark of Advanced Partnerships LLC.