We care... so we don't share.
Access Marketing & Communications LLC, dba Scrimmage
EFFECTIVE: April 20, 2021
Introduction and Scope
PII We Process
Categories of PII
PII that is provided to us could include biographical information such as your first and last name, contact information such as your street address, telephone number, and email address, information about your profession, and any other information we collect about you that by itself may not be PII but if combined with PII could be used to personally identify you.
How we Receive PII
We may receive your PII when:
- you or a colleague registers for our Services, or registers and/or sets up an account to access and use our Services;
- you submit a support ticket; and
- you engage in any other transactions with us on or in relation to our Services.
Information We Automatically Collect
When you use our Apps, whether by computer, mobile phone, or other device, we automatically collect certain data about your use of our Apps (this information may include without limitation: geographical location and IDs of your computer, mobile or other device; bandwidth used; system and connection performance; browser type and version; operating system; referral source; length of visit; page views; your mobile carrier; IP address or other unique identifier for your computer, mobile phone or other device). We use technologies such as cookies and web beacons for this purpose.
A "cookie" is a small file stored on your hard drive that contains information about your computer. By showing how and when visitors use the application, cookies help us save user preferences and track user trends and patterns. We use session cookies, which are cookies that are deleted when you leave our application and persistent cookies, which are cookies that remain after you leave our application so that you are recognized when you return.
We may use web beacons (also known as clear GIFs) to access cookies and count users who visit our web application or open our HTML-formatted email messages. Web beacons are single-pixel graphic files with a unique identifier, similar to cookies. Web beacons are embedded invisibly on web pages and are stored on a user's hard drive. You can modify your browser settings to control web beacons.
Responding to Do Not Track Signals
Our Apps do not have the capability to respond to “Do Not Track” signals received from various web browsers.
How We Use Your PII
Basis of Processing
Purposes of Processing
Scrimmage may use your PII to:
- enable the use of our Services; and
- respond to your inquiries, and/or other requests or questions.
With regard to automatically collected data, we may use such non-personally identifying information to improve your experience with our Services.
We may use IP addresses to help diagnose problems with our server, analyze trends, track users' movement, gather broad demographic information for aggregate use in order for us to improve our Services, and deliver customized content.
Data Retention Periods
When the purposes of processing are satisfied, we will delete the related PII within one month.
Sharing PII with Third Parties
We may use third parties to perform certain services on our behalf. We may share your PII with these third parties solely to enable them to perform the services for us.
Such third parties include those:
- hosting our Services;
- providing cloud storage; and
- providing a support ticketing system.
We require that those third-party vendors maintain at least the same level of confidentiality and data protection that we maintain for such PII. We do not provide your PII to parties unconnected with our Services.
Scrimmage remains liable for the protection of PII that we transfer to our service providers within the scope of our Privacy Shield certification, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.
Disclosure of PII
We may disclose your PII:
- to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
- if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or
- to our subsidiaries or affiliates only if necessary for business and operational purposes.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about the users of our Services as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.
Scrimmage has implemented and will maintain commercially reasonable technical and organizational security measures to protect PII from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction. Unfortunately, data transmission over the Internet is never 100% secure so we cannot guarantee the security of any information you transmit to us or from our Apps, therefore you use our Services at your own risk.
Accessing / Limiting the Use and Disclosure of Your PII
If you are a data subject about whom we store PII, you may have the right to request access to, and the opportunity to update, correct, or delete such PII. If we have received your PII in reliance on the Privacy Shield, you may also have the right to opt out of having your PII shared with third parties and to revoke your consent to our sharing your PII with third parties. You may also have the right to opt out if your PII is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized.
To submit such requests, please contact the party that has provided your PII to us (e.g., your employer). We have limited rights to access the PII our customers submit to us. Therefore, if you choose to contact us with such a request, please provide the name of our customer who submitted your PII to us. We will forward your request to that customer and provide any needed assistance as they respond to your request.
If you have provided your PII to us directly or if you want to raise any other questions related to the way we process your PII, please contact us using the information in the Contact Information section of this Policy.
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
To learn more about the Privacy Shield, and to view Access Marketing & Communications LLC, dba Scrimmage’s certification, please visit https://www.privacyshield.gov and https://www.privacyshield.gov/list, respectively.
VeraSafe Privacy Program
Where a privacy complaint or dispute cannot be resolved through Scrimmage’s internal processes, Scrimmage has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/.
If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.
Scrimmage is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Attn: Kumar Erramilli, Chief Technology Officer
Access Marketing & Communications LLC, dba Scrimmage
60 Atlantic Avenue, Suite 200
Toronto, ON M6K 1X9
Please allow up to two weeks for us to reply.