Remote Scouts Privacy Policy

Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Remote Scouts
Our representative	Attn: Compliance Department Email: info@remotescouts.com Address: 5230 Las Virgenes Rd., Suite 210 Calabasas, CA 91302
Our data protection officer	Attn: Data Protection Officer Compliance Department Address: 5230 Las Virgenes Rd., Suite 210 Calabasas, CA 91302 Email: info@remotescouts.com
Personal information	Any information relating to an identified or identifiable individual.
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; Genetic and biometric data; Data concerning health, sex life or sexual orientation.
Site	“Site” refers to Remote Scouts ’s website(s), payment processing website, and our consumer portal.
Remote Scouts Parties	Us and our agents, employees, assigns, affiliates, contractors, and subcontractors (collectively “Remote Scouts Parties”)

1. Personal Information We Collect About You. You can examine this Site without providing any information whatsoever, however, certain information such as identifiers, geolocation data, and device/system information, as further described below, is collected in accordance with our use policies below. This Site’s contact request functions require users to give us contact information. This information is used to provide information to those who inquire about our products and services and to handle related business matters. This information is also used to get in touch with you when necessary. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)	Real name, email address, phone number, postal address, and all data you enter using the Site.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.	Name, signature, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. We do not log bank account numbers or credit card numbers used on our Site.
Commercial information	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
System, internet, or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, or application) and cookies	Browsing and search history on our Site, time you spend on our site, pages, and sections you view on our Site, length of visits to pages, mobile applications you use, and device information, including location, Internet protocol (IP) address, screen resolution, device type, device and advertisement identifiers, browser type, and operating system, the date and time of your visit, information about the links you click and pages you view within the Sites, e-mail address used, browser time zone, and page activity information.
Geolocation data	We collect your location information through your device IP address available through your device.
Audio information	We collect identifiers and information that identifies, relates to, describes, or is capable of being associated with, a particular individual through recorded phone calls with our office.
Professional or employment-related information	Title/position, company name, earnings, and related information.
Education information, defined as information that is not publicly available personally identifiable information.	Information about the university, college other institutions you have or are attending, tuition, financial information, degree or level of education, and related information.
Inferences drawn from any of the information identified above to create a profile about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	We may use the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

This personal information is required to provide products and services to you. If you do not provide personal information when we ask for, it may delay or prevent us from providing products and services to you.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, email and/or via our website. However, we may also collect information:

• From publicly accessible sources;
• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
• From a third party with your consent (e.g., your bank); and
• From cookies on our website.

Remote Scouts Parties may use technology in order to better understand your needs and to optimize our services and user experience. This technology may record sessions of how much time you spend on certain pages; which links you choose to click; where you click, scroll your mouse, and move in between pages; what you do and don’t like; and the like. We use this information to create visual representations (“Session Recordings”) of the experience. This enables us to build and maintain our Site and services with your feedback. Session Recordings reconstruct the individual actions you took during a website visit. Heatmaps aggregate data points from you and hundreds of other visitors in one report.

We use cookies, Session Recordings, heatmaps, and other technologies to collect data, behavior, and device information. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. This information is stored on our behalf in a pseudonymized user profile. We do not sell any of the data collected.

By accessing this Site, you expressly agree to our use of cookies, Session Recordings, heatmaps, and other technologies to collect your information and the way we treat or use your information. You also agree to us sharing your information with our vendors, affiliates, and subcontractors, as necessary, to help facilitate our services.

4. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• To comply with our legal and regulatory obligations;
• For the performance of our services for you and clients or to take steps at your request;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and/or services to you.	For the performance of our contracts with clients or to take steps at your request.
To prevent and detect fraud against you or our organization.	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you.
Conducting checks to identify individuals with whom we transact business and verify their identity. Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our regulators.	To comply with our legal and regulatory obligations. To comply with our legal and regulatory obligations. To comply with our legal and regulatory obligations.
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies.	To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to, e.g. policies covering security and internet use.	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training and quality control.	For our legitimate interests or those of a third party, i.e. to be as efficient as we can.
Ensuring the confidentiality of commercially sensitive information.	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.
Preventing unauthorized access and modifications to systems.	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations.
Updating and enhancing customer records.	For the performance of our contract with clients or to take steps at your request. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.
Ensuring safe working practices, staff administration and assessments.	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Credit reference checks via external credit reference agencies.	For our legitimate interests or those of a third party, i.e. to review credit reports for information that will aid in the services we offer our clients.
External audits and quality checks, e.g. for accreditation and the audit of our accounts.	For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations. To comply with our legal and regulatory obligations.
When you visit this Site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.	Functional cookies enable this Site to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly. Analytics cookies track and gather data about what a user does on a website. These cookies are not essential for our website or its functionality to work. We use Google Analytics cookies. They are classified as first party cookies as they are set by our website domain, although Google collects and processes information from our use of Google Analytics. To find out more about how Google handles information collected from Google Analytics, see Google Analytics’ privacy policy. For information on how Google uses data from cookies it uses, please visit Google’s Privacy Policy. Essential cookies are cookies which are strictly necessary for our Site to be able to operate or to provide you with a service on our Site which you have requested.

5. Account Communications. We may use your personal information to send you updates (by email, text message, telephone, or post). If you provide us with a telephone number and/or e-mail address, you are consenting to receive auto dialed, prerecorded/artificial voice message calls and text messages at that number, or e-mail messages at that e-mail address, from us or from third parties that work for us, even if the number you provide is for a wireless telephone and/or using that number results in charges to you. Calls with Remote Scouts Parties may be monitored or recorded.

Remote Scouts Parties will use your e-mail address(es) in accordance with the Site Terms and Conditions. However, this does not mean that e-mail will be used as an exclusive means of communication and Remote Scouts Parties may use other information provided by you to communicate with you. Because e-mail continues to evolve, there may be risks with communicating in this manner, including risks related to confidentiality and security.

You may have the right to receive certain information and documents in paper or non-electronic form. If you want to withdraw consent to receive documents and information by e-mail, Remote Scouts Parties may not be able to communicate with you.

By providing your cell phone number or confirming or updating your contact information using this Site, you agree to receive SMS text messages on your mobile device. By agreeing to receive SMS messages from Remote Scouts, you certify that you are over 18 years of age and (a) you are the mobile account holder or (b) you have the account holder’s permission to enroll the designated mobile phone number and can incur any mobile message or data charges. You agree that you are solely responsible for all message and data charges that apply to use of your mobile device to access this Site or use of a mobile application. All such charges are billed by and payable to your mobile service provider. Please contact your participating mobile service provider for pricing plans, participation status and details. You understand that wireless through Wi-Fi or a participating mobile service provider may not be available in all areas at all times and may be affected by product, software, coverage or other service changes made by your mobile service provider or otherwise.

We have a legitimate interest in processing your personal information for our services (see above “How and why we use your personal information”). This means we do not usually need your consent to attempt to communicate with you. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to other organizations for marketing purposes.

You have the right to opt out of receiving communications at any time by:

• Contacting us at info@remotescouts.com; or
• Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We may share personal information with the following, if permissible by applicable law, to operate our business and provide our products and services.

• Service providers, vendors, and subcontractors we use to help deliver our products and/or services to you, in accordance with applicable law(s);
• Information providers;
• Third parties approved by you, including third-party payment providers;
• Credit reporting agencies;
• Our insurers and attorneys;
• Our banks;
• Our parent, subsidiaries, and affiliates, when necessary (e.g., to provide products or services, or as part of a merger, acquisition or corporate restructuring); and
• With state and federal regulators in accordance with a lawful order, request, or inquiry.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have not sold any personal information to third parties. In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, passport number, or other similar identifiers);
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, passport number, or identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information;
• Commercial information (e.g., records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• System, internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, or application), cookies, and geolocation data;
• Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures;
• Audio recording information;
• Professional or employment-related information;
• Education information, defined as information that is not publicly available personally identifiable information; and
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We have not sold to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

8. Where Your Personal Information is Held. Information may be held at our offices and if permissible by law, those of our service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). Some of these third parties may be based outside the United States.
9. How Long Your Personal Information Will Be Kept. We will keep your personal information while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law and retention policy.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

10. Transferring Your Personal Information Out of the United States. To deliver services to you, it is sometimes necessary for us to share your personal information outside the United States, e.g.:

• With our offices outside the U.S.;
• With your and our service providers located outside the U.S.;
• If you are based outside the U.S.; or
• Where there is an international dimension to the services we are providing to you.

11. Your Rights Under the CCPA. You may have certain rights under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: • The categories of personal information we have collected about you; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting or selling personal information; • The categories of third parties with whom we share personal information, if any; and • The specific pieces of personal information we have collected about you. Please note that we are not required to: • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and • The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. However, we do not sell your personal information.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: • Delete your personal information from our records; and • Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: • Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

12. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
13. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please email us at info@remotescouts.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by website, email, phone or in writing, you will need to provide us with:

• Enough information to identify you [(e.g., your full name, address and customer or matter reference number)];
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

14. Changes to This Privacy Notice. This privacy notice was published on May 26, 2021 and last updated on March 22, 2023.

We may change this privacy notice from time to time–when we do, we will inform you via website or other means of contact such as email.

15. How to Contact us. Please contact us if you have any questions about this privacy policy or the information we hold about you at:

Data Protection Officer Remote Scouts

5230 Las Virgenes Rd., Suite 210 Calabasas, CA 91302

info@remotescouts.com

(818) 474-4107