1. PURPOSE AND INTENT
This Policy supplements and forms a part of the Terms and Conditions.
2. INFORMATION USE
When you visit our website (“Site”) or engage with one of our Independent Consultants through the Penny Mobile Application (“Penny”), we may collect certain personal information you knowingly choose to disclose to us, such as your name, email address, address and phone number. You may provide this information when you register with the Site, purchase products from the Site, express interest in becoming a Scout & Cellar Consultant or Member or communicate with us.
Scout & Cellar passively collects non-personal information that is automatically sent to us by your web browser or device including but not limited to your domain name and username.
We may also collect aggregated information as you visit the Site.
We may use the information we collect from your browser or device to:
- respond to your inquiries;
- provide information to you in response to your inquiries;
- provide service and support to our Independent Consultants, Customers and Members;
- fulfill orders;
- operate the Site and/or Penny and customize your experience;
- provide customized content, advertising and services;
- identify or correct potential threats to the Site’s security;
- report sales for regulatory purposes;
- conduct research about your use of the Site and our services;
- Send you a communication via email, text or app message inviting you to shop with a consultant as part of our leads distribution program; and
- for any other purpose stated at the time of collection.
You may opt out of marketing emails, including but not limited to emails inviting you to shop with a consultant, by unsubscribing to our marketing email distribution list. To unsubscribe, click the “Unsubscribe” button at the bottom of any of our marketing emails.
3. COOKIES AND ANALYTICS
This Site is cookie-enabled to give you a more customized user experience. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Cookies are used to collect information on the number of visitors to our Site and the number of pages viewed. It is also used to provide relevant information to our visitors and for Site and system administration, including research and development, user analysis and business decision-making.
We may also use Google Analytics to collect non-personally identifiable information regarding visitor behavior and visitor demographics on some of our Services and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and processing of data here: https://tools.google.com/dlpage/gaoptout.
4. DATA PROTECTION PRINCIPLES
We will comply with applicable data protection law, which provides that the personal information we hold must be: (i) used lawfully; (ii) collected only for valid purposes and not used in any way that is incompatible with those purposes; (iii) relevant to the purposes we have disclosed and limited only to those purposes; (iv) accurate and kept up to date; (v) kept only as long as necessary for the purposes we have disclosed; and (vi) kept securely.
5. RESIDENTS OF CALIFORNIA - WHAT PERSONAL INFORMATION IS COLLECTED AND HOW IT IS USED
For Consultants and former Consultants, please refer to the INDEPENDENT CONSULTANT AGREEMENT CCPA ADDENDUM and the PRIVACY NOTICE TO CALIFORNIA INDEPENDENT CONSULTANTS REGARDING THE COLLECTION OF PERSONAL INFORMATION (available here) for the information collected by Scout & Cellar from Consultants, what we do with it, and the obligations that Consultants have with regards to personal information protected by the CCPA. Each of these documents are available in The Cellar.
We will only use your personal information for the purposes we have disclosed in our notices described in paragraphs above.
6. DATA SECURITY
While no data security system can fully protect personal information from unauthorized data breaches, Scout & Cellar has implemented reasonable safeguards and controls, consistent with its legal obligations. Scout & Cellar is committed to: (i) seeking to safeguard all personal information to us; (ii) seeking to ensure that it remains confidential and secure; and (iii) taking all reasonable steps to ensure that personal privacy is respected. All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information of consultants to only those consultants, and third parties who need to know that information for the purposes identified in our notice(s) discussed in the paragraphs above. Scout & Cellar provides consumer’s personal information to consultants as service providers and pursuant to the consultant’s contractual obligations to comply with all necessary privacy protections. Scout & Cellar does not share consumer personal information with third parties. See the notices discussed in the paragraphs above.
We have put in place procedures to deal with any suspected data security breach and will notify those subject to the breach and any applicable regulator of a suspected breach where we are legally required to do so.
7. DATA RETENTION
We will only retain personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize personal information so that it can no longer be associated with an individual, in which case we may use such information without further notice.
Once an individual is no longer a consultant, and or customer of Scout & Cellar, we will retain and securely destroy personal information in accordance with Scout & Cellar’s record retention policies.