Scaling.com, LLC Privacy Policy

Please read this Privacy Policy carefully.

SCALING.COM, LLC (“Company”, “we”, “us”, and “our”), is committed to ensuring the security

and protection of the personal information that we collect. This Privacy Policy includes (a) our

products or services and processes, which may result in the collection of personal data; (b) the

purpose for processing personal data; (c) the persons or entities with whom we share personal data;

and (d) how long we maintain personal data. This Privacy Policy applies to:

-All information we collect through the products, events, promotions, surveys, contests and

all other services (collectively, the “Services”) provided on our websites, applications and

platforms, including mobile websites, applications and platforms, any affiliated or non-

affiliated third party sites, and all social media platforms (collectively, the “Sites”); and

-All current, potential and former employees, users, independent contractors, vendors, third

parties and/or any other person whose personal data we have collected electronically, in

person or otherwise.

Special Note: The Sites are general audience sites and are not designed or intended to target children

younger than 16. We do not knowingly target or collect personal information from any person

younger than 16.

What Information Do We Collect?

Information We Collect Automatically. If you use the Sites, read or download information, your

web or mobile browser may automatically send us your internet or other network activity including

one or more of the following (collectively, “Network Information”):

-Your internet protocol (IP) address, registration date, and one or more cookies that may

uniquely identify your browser;

-Your internet domain and the specific path, actions and navigation choices;

-The internet address of the site from which you linked the Sites, and the time and date you

accessed the Sites;

-Your browsing history, search history, information on your interaction with the Sites or

other websites and applications or advertisements; and

-Your browser software, operating system and browser language, and information about your

location and mobile device, including a unique identifier for the mobile device.

Why We Collect: We collect this information for business and commercial purposes, including in

order to:

✔ Maintain or analyze the functioning of the Sites or Services and to maintain network

communications;

✔ Monitor and analyze web traffic and online behavior for search engine optimization and

social media marketing;

✔ Host data files that enable the Sites to function, be distributed, and to provide specific

features or parts of the Sites;

✔ To create, maintain, customize, secure, and manage your accounts with us, including for

accounting, finance, and dispute resolution purposes (such as accounts receivable, accounts

payable, account reconciliation, cash management, or money movement) and for

consolidated management and reporting;

✔ To personalize your experience on the Sites and to deliver content and Services relevant to

your interests and requests through our Sites (with your consent as required by law);

✔ To process your requests, purchases, transactions, and payments and to prevent financial

fraud and other illicit activity;

✔ For testing, research analysis, and product development, including to develop and improve

the Sites and Services;

✔ Initiate, assess, develop, maintain, or expand a business relationship, including negotiating,

contracting, and fulfilling obligations under contracts;

✔ Manage a database of email information, phone information or other information and send

transactional communications (such as requests for information, responses to requests for

information, orders, confirmations, training, and service updates);

✔ Assure quality control and to enforce Company’s standards and policies;

✔ Manage security, including monitoring individuals with access to the Sites and Services,

applications, systems, or facilities, investigation of threats, and as needed for any data

security breach notification;

✔ Manage relationships with current and potential customers and for marketing purposes,

including sending marketing, promotional, product and service, and customer

communications and surveys and other communications to individuals who have not

objected to receiving such communications;

✔ Anonymize or de-identify the personal information;

✔ View and incorporate content hosted on external sites;

✔ Respond to law enforcement requests and as required by applicable law, court order, or

governmental regulations; and

✔ Process payment information and transactions.

Information You Give To Us and Information We Collect From Others. If you use the Sites

or Services, or you otherwise use or purchase our Services, we receive and store information you

enter on the Sites, or that you give us in-person, via telephone, email, or otherwise. We may also

collect personal information from third parties that operate (a) portions of the Sites and Services on

our behalf or (b) independent websites. When we obtain personal data from third parties, we will

treat the acquired information like the information that we collect ourselves. Depending on the

Services we provide to customers and/or the services being provided to us by other third parties, we

may collect (and over the previous 12 months have collected) the following information about you

from you and/or others:

✔ Network Information;

✔ Personal information and identifiers, such as name, postal address, email address, telephone

numbers, account name, social security number, driver’s license or state identification card

number, passport number or other similar information, physical characteristics or

description, insurance policy number, education, employment, employment history, bank

account number, credit card number, debit card number, or any other financial information,

medical information, or health insurance information (collectively, “Personal Information

and Identifiers”);

✔ Protected classification information, such as race, color, ancestry, national origin, citizenship,

religion or creed, marital status, medical condition, physical or mental disability, sex

(including gender, gender identity, gender expression, pregnancy or childbirth and related

medical conditions), veteran or military status, sexual orientation or other similar

information (collectively, “Protected Class Information”);

✔ Commercial information, such as the Services purchased, obtained or considered, or other

purchasing or consuming histories (collectively, “Commercial Information”);

✔ Biometric and identifying information, such as fingerprints, faceprints, voiceprints, iris or

retina scans, keystroke, gait or other physical patterns, and sleep, health or exercise data,

genetic, physiological, behavioral and biological information or other similar information

(collectively, “Biometric Information”);

✔ Sensory data, such as audio, electronic, visual, thermal, olfactory or similar information

(collectively, “Sensory Information”);

✔ Geolocation data, such as physical location or movements (collectively, “Geolocation

Information”);

✔ Professional or employment-related information, such as work history and job descriptions

with current and prior employers (collectively, “Employment Information”);

✔ Education information, such as student financial information, grades, transcripts, class lists

and other records related to a student maintained by an educational institution or party

acting on its behalf (collectively, “Education Information”); and

✔ Inferences drawn from any of the personal information listed above to create a profile or

summary, such as, for example, an individual’s preferences, abilities, aptitudes,

predispositions, and characteristics (collectively “Profile Information”).

Why We Collect: We collect this information for business and commercial purposes, including in

order to:

✔ To create, maintain, customize, secure, and manage your account with us, including for

accounting, finance, and dispute resolution purposes (such as accounts receivable, accounts

payable, account reconciliation, cash management, or money movement) and for

consolidated management and reporting;

✔ To personalize your experience on the Sites and to deliver content and Services relevant to

your interests and requests through our Sites (with your consent as required by law);

✔ To process your requests, purchases, transactions, and payments and to prevent financial

fraud and other illicit activity;

✔ For testing, research analysis, and product development, including to develop and improve

the Sites and Services;

✔Initiate, assess, develop, maintain, or expand a business relationship, including negotiating,

contracting, and fulfilling obligations under contracts;

✔ Perform due diligence regarding an individual’s qualifications and eligibility for the Services,

including verifying the identity, qualification, authority, and creditworthiness of the

individual and obtaining publicly-available information from third parties (such as publicly-

available sanction lists from screening companies);

✔ Manage a database of email information, phone information or other information and send

transactional communications (such as requests for information, responses to requests for

information, orders, confirmations, training, and service updates);

✔ Assure quality control and to enforce Company’s standards and policies;

✔ Manage and mitigate risk, including for audit and insurance functions, and as needed to meet

our obligations and to protect assets;

✔ Manage security, including monitoring individuals with access to the Sites, applications,

systems, or facilities, investigation of threats, and as needed for any data security breach

notification;

✔ Monitor and analyze web traffic and online behavior for search engine optimization and

social media marketing;

✔ Host data files that enable the Sites and Services to function, be distributed, and to provide

specific features or parts of the Sites and/or Services;

✔ Manage relationships with current and potential customers and for marketing purposes,

including sending marketing, promotional, product and service, and customer

communications and surveys and other communications to individuals who have not

objected to receiving such communications;

✔ Anonymize or de-identify the personal information;

✔ View and incorporate content hosted on external sites;

✔ Respond to law enforcement requests and as required by applicable law, court order, or

governmental regulations; and

✔ Process payment information and transactions.

How We Collect Information From Customers. Pursuant to our agreements with customers, and

in order to perform and provide the Services thereunder, our customers may provide us with

information about their clients, employees and contractors when using the Sites or Services.

How We Collect Information From Other Third Parties. We may use cookies to recognize you

when you return to the Sites in order to provide you with a better user experience. We also allow our

affiliates and third-party vendors to use cookies on our Sites; some of these parties may use cookies

in ways that we do not. You may refuse to accept cookies by activating the setting on your browser

which allows you to refuse the setting of cookies. However, if you select this setting you may be

unable to access certain parts of the Sites. Unless you have adjusted your browser setting so that it

will refuse cookies, our system will issue cookies when you log onto our Sites.

-Facebook, Instagram, & Google. Technologies like cookies, pixel tags, device or other

identifiers and local storage are used to deliver, secure, and understand products, services, and ads,

on and off Facebook, Instagram, Twitter, LinkedIn, YouTube, and related social media platforms.

They also are used to gather information for remarketing to similar audiences on our Sites. Because

of this, third-party vendors, including Google, show our ads on sites across the internet. This

technology allows third-party vendors, including Google, to use cookies to serve ads based on

someone’s past visits to our Sites. You may opt out of Google’s use of cookies by visiting Google’s

Ads Settings. You may also opt out of a third-party vendor’s use of cookies by visiting the Network

Advertising Initiative opt-out page.

Do We Share Information With Third Parties?

We take reasonable precautions to be sure that nonaffiliated third parties and affiliates, to whom we

disclose your personally identifiable information are aware of this Privacy Policy and will treat the

information in a similarly responsible manner. Our contracts and written agreements with

nonaffiliated third parties that receive information from us about you prohibit those parties from

transferring the information other than to provide the Services that you obtain from us.

Over the previous 12 months, we have shared the following categories of personal information with

third parties: Personal Information and Identifiers, Protected Classification Information,

Commercial Information, Biometric Information, Network Information, Sensory Information,

Geolocation Information, Employment Information, Education Information, and Profile

Information.

We will not disclose your personal information to third parties except to provide you with

information or services you request, deliver our Services that include your personal information, or

under certain circumstances as described in this Privacy Policy, including:

Your Consent. We may share personal data with your consent.

Disclosure For Legal Reasons. We may release personal data to third parties: (1) to comply with

valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in

special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our

system or network, or cases in which we believe it is reasonably necessary to investigate or prevent

harm, fraud, abuse, or illegal conduct. We may also disclose personal data where needed to affect the

sale or transfer of business assets, to enforce our rights, protect our property, or protect the rights,

property or safety of others, or as needed to support external auditing, compliance and corporate

governance functions.

Agents & Contractors. Our contractors sometimes have access to your personal data in the course

of assisting in the operation of our business and providing Services to you. These contractors

include vendors and suppliers that provide us with technology, services, and/or content for the

operation and maintenance of the Sites and the Services. Access to your personal information by

these contractors is limited to the information reasonably necessary for the contractor to perform its

limited function. Contractors have an obligation under their contracts with us to keep your

information confidential and to comply with our privacy and security policies.

Links To Other Sites. The Sites may contain links to other websites and resources located on

servers maintained by third parties. These links are provided for your convenience and information

only and, as such, you access them at your own risk. When you click on one of those links, we will

not provide any personal information about you, but may let the site know that you came from the

Sites. We do not control the privacy practices and policies of other sites. Please read their privacy

policies in order to understand what information they collect about you and how they use it.

Aggregated, Non-Personal Information. We may share aggregated, non-personal information

about you with third parties. This is information that is combined with the non-personal

information of other users and does not allow you to be identified or contacted. Depending on the

circumstances, we may or may not charge third parties for this aggregated information. We also may

not limit the third parties' use of the aggregated information.

Changes In Our Corporate Structure. If all or part of the Company is merged, acquired or

otherwise transferred to another entity, the personal data you have provided to us may be

transferred as part of that transaction. We will take steps to ensure that any personal data that is

transferred will not be used or shared in a manner inconsistent with this Privacy Policy, as it may be

amended.

Do We Sell Your Personal Information?

No. Although the Company shares data with third parties as outlined in this Privacy Policy, the

Company does not sell any of your personal information to any third party.

How and Where Do We Process and Store Data?

Methods of Processing. The data processing is carried out in accordance with our privacy

procedures and policies and using computers and/or related software and IT tools. In some cases,

the data may be accessible to certain types of (i) internal parties in charge or involved with the

operation of our Sites and Services (i.e., administration, legal, sales and marketing, etc.) or (ii)

external parties who assist us in providing, operating, and maintaining our Sites and Services, (i.e.,

third-party technical service providers, mail carriers, hosting providers, communications agencies,

etc.). Still, we notify both internal and external parties of this Privacy Policy and require that internal

parties (through employment agreements and related employment policies) and external parties

(through written agreements) keep and maintain the data in accordance with the safeguards

described in this Privacy Policy and related policies and procedures.

Third Party Processing. We assess and review each of our third party processers to ensure that

they are in compliance with this Privacy Policy.

How Do We Protect Personal Data?

The Company protects data using administrative, technical, and physical safeguards. When we use

third-party service providers, we ask those providers to implement similar safeguards. However, we

cannot guaranty that your information is completely secure either within the Company or on the

systems of third party service providers.

How Long Do We Keep Your Personal Data?

We retain personal data we collect from you when we have an ongoing legitimate business need to

do so (i.e., to provide you with the Services you have requested or to comply with applicable legal

requirements). When we no longer have an ongoing legitimate business need to process your

personal information, we will physically destroy, delete or anonymize it or, if this is not possible,

then we will securely store your personal data and isolate it from any further processing until

deletion is possible.

California Residents

If you are a resident of California, please read the California Privacy Notice for more information regarding your privacy protections and privacy rights pursuant to the California Consumer Privacy

Act of 2018, as amended.

How To Contact Us

If you have any questions regarding this Privacy Policy or exercising any of your privacy rights,

please contact us at the telephone number, email address or mailing address listed below:

Telephone Number: (385) 853-5426

Email Address: [email protected]

Mailing Address: 4844 N 300 W STE 300, Provo, Utah, USA, 84604

Changes To This Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make

changes to this Privacy Policy, we will give notice to you via (i) the Sites or (ii), where feasible, and at

our discretion, contact information available to us. We encourage you to periodically review this