Privacy Policy

We may consolidate the information as detailed above with information that we receive or obtain from other sources, such as from our staff or personnel, customers, professional advisers, partners, and agents of Serving Score, third parties with whom we interact, regulators and authorities, and publicly available sources.

 

Under GDPR, “sensitive personal information” includes data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. We do not actively seek sensitive personal information; however, we may, in the future, collect (a) racial or ethnic origin information that you as an employee voluntarily provide to us in order for us to comply with applicable employment laws; (b) and potentially fingerprint or facial recognition data as a means for employees to use the company’s timekeeping system for employees or to access our offices or centers within our offices; and (c) health information in connection with the securing and provision of health and related benefits programs for our employees.

 

In addition to the specific uses noted above, we also note that we may use information that we receive in all categories, as necessary (a) for our legitimate interests to prevent illegal activities, including fraud, and to keep our website, mobile application and IT systems and processes safe, (b) to debug and audit our systems and data, (c) to comply with legal or regulatory inquiries/requests, (d) for quality assurance purposes, and (e) to comply with corporate governance requirements.

 

In this regard, we note that we may be required to share information that we receive in the following situations generally:

• with law enforcement, regulatory, or government agencies requesting personal information in connection with any inquiry, subpoena, court order, or other legal or regulatory procedures, with which we would need to comply;

• to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others;

• to defend against legal claims;

• in connection with a reorganization, restructuring, merger, acquisition, or transfer of assets of our Company, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.

 

The Systems We Use to Collect and Process the Information

 

We may collect information directly from you, as detailed above, and we may also gather information about you as we conduct our business such as through our website, our mobile application and other systems, including, for example, our:

• email system

• instant messaging systems

• mobile and office phone systems, including voicemail and related software and also the records relating to such use

• intranet and Internet systems

• computer network

• other relevant systems and other hardware and software owned, used or provided by or on behalf of us.

 

We are not responsible for the data policies or procedures or content of any linked websites. We recommend that you check the privacy and security policies of each website you visit.

 

We Offer Marketing Choices

 

We may send you direct marketing messages including by way of email alerts, text messages and postal services provided that we have a lawful ground to do so. If you no longer wish to receive our email alerts or text messages, to be part of a mailing list, or to receive any marketing communications, you can opt-out of such communications at any time by clicking on the unsubscribe link in the relevant communication or contacting us at info@servingscore.com.

 

Special Rights Regarding Personal Information

 

1. Residents of the EU (please note that we do not currently actively market our products or services in the EU, so we are not currently actively collecting any personal information from persons in the EU; however, to the extent that that changes, we are guided by the following considerations):

 

If you are in the European Economic Area (the “EEA”), you have the following rights under the GDPR:

• Access - to request a copy of the personal information that we are processing about you;

• Rectification - to require the correction of any mistake in the personal information, whether incomplete or inaccurate, that we have regarding you;

• Erasure - to require the erasure of personal information concerning you in certain situations, such as where we no longer need it or if you withdraw your consent (where applicable);

• Portability - to receive the personal information concerning you that you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to a third party in certain situations;

• Objection - to (i) object at any time to the processing of your personal information for direct marketing purposes and (ii) object to our processing of your personal information where the legal ground of such processing is necessary for legitimate interests pursued by us or by a third party, in which case we will comply with your request unless we can demonstrate compelling legitimate grounds for the processing;

• Restriction - to request that we restrict our processing of your personal information in certain circumstances, such as when you contest the accuracy of that personal information, we no longer need the information. or if our processing is unlawful;

• Withdrawal of consent – to withdraw your consent to our processing of your information if we have relied on your consent (or explicit consent) as our legal basis for processing your personal information (“Explicit consent” being required if we have relied on consent as the condition to lawfully process “special categories of personal data,” as defined in the GDPR);

• Notification of data breach – to receive notice in certain instances of data breaches that involve your personal information; and

• Complain - to lodge a complaint with the local data protection authority, such as the Information Commissioner's Office (“ICO”) in the UK, if you believe that we have not complied with applicable data protection laws, including the GDPR (please follow this link for a list of local data protection authorities in the EEA countries: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).

 

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal information or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

 

If you are in the EEA and would like to exercise any of those rights, please:

• Email our Data Protection Officer at mark.absher@servingscore.com;

• Provide enough information to identify yourself (e.g., name, email address, etc.);

• Provide proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill); and

• Provide the information to which your request relates.

 

2. Residents of California

 

The CCPA does not currently apply to us, because we have not come within the scope of any of its applicable standards; however, in the event that the CCPA becomes applicable to us, we will be guided by the following considerations: 

 

We do not sell or lease personal information to any party, and we do not provide personal information to any parties except as specifically detailed in this Privacy Policy. If you are a California resident, you have the following rights, subject to certain exceptions as set forth in the CCPA:

• Access - to receive the specific pieces of your Personal Information we have collected about you in the 12 months preceding your request;

• Portability - to receive a copy of your electronic personal information in a readily-usable format;

• Information Regarding Sources and Purposes - to receive information from us regarding the categories of personal information we collected, the sources from which we collect personal information, the purposes for which we collected and shared personal information, the categories of any personal information we sold as well as the categories of third parties to whom such personal information was sold, and the categories of personal information that we disclosed for a business purpose in the 12 months preceding your “right to know” request;

• Deletion - to request the deletion of the personal information that you provided to us. Please note that in certain instances we may not be able to process your request, such as (i) due to the existence of a legal obligation, (ii) to detect security incidents, (iii) to protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, or (iv) in order to complete a transaction for which your personal information was collected; and

• Non-Discrimination - to be free from discrimination by us with regard to pricing or performance as a result of you exercising your rights under the CCPA.

 

If you wish to exercise these rights, you must submit a request by emailing our Data Protection Officer at mark.absher@servingscore.com. The CCPA requires us to verify requests we receive when one is seeking to exercise certain of the rights listed above. We may ask you to provide certain information in order for us to verify your request.

 

With regard to your rights under the CCPA, we note in the table above we detail the personal information that we have collected about California residents in the last 12 months, as well as the sources from which we obtain the listed categories of personal information and the parties with whom such information has been shared.

 

In the preceding 12 months, we have not sold any personal information.

 

3. Minors and Children

 

We do not seek to collect or maintain information on our website or through our mobile application from those we know are under 18, and no part of our website or mobile application is structured to attract anyone under 13. If you are the parent or legal guardian of a child under 13 who uses our website or mobile application, then please contact our Data Protection Officer at info@servingscore.com to have that child’s information deleted. “OnGuard Online,” maintained by the Federal Trade Commission of the United States of America, provides a resource that may help parents and legal guardians in monitoring and limiting their children’s access to certain types of material on the Internet.

 

Our Security Measures to Safeguard the Information

 

Consistent with our operational maturity as a start-up organization with a virtual presence, we have implemented technical and organizational security measures in an effort to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to staff and authorized service providers on a need-to-know or contract limiting basis for the purposes described in this Privacy Policy, as well as other administrative, technical, and physical safeguards.

We endeavor to take all reasonable steps to protect your personal information but cannot guarantee the security of any data you disclose online. Please note that email is not a secure medium and should not be used to send confidential or sensitive information. By providing information online, you accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security, unless it is due to our negligence or willful default.

 

When We Transfer Information Internationally

 

We do not currently market our products and services outside of the United States.  In the event that we do so in the future, we will be guided by the following considerations: Your personal information may be transferred to or shared across our integrated computer networks with one or more of our vendors in other countries that may not be subject to data protection laws similar to those prevailing in the jurisdiction in which such information is provided to or received by us. However, we will endeavor to assure that our vendors adhere to the same or similar procedures with respect to your personal information, including this Privacy Policy.

 

In the event that it becomes necessary to transfer personal information from the United Kingdom or the EEA to a country outside the EEA (or to an international organization), such actions would be taken in order to provide our staff with access to the personal information of a customer, vendor or supplier or representative of a customer, vendor or supplier, to enable them to perform our contracts and provide support for our or obtain their products and services, wherever they are located, and for related purposes as set out in this Privacy Policy.

 

Cookies

 

A cookie is a small file of letters and numbers that is sent by our web server to your computer or mobile device when you access our website. Our website may use persistent cookies, which enable our web server to recognize your device and browsing preferences each time you visit our website. For more information on cookies, visit www.allaboutcookies.org.

 

We use cookies only for the purposes set forth in the table above.

 

Cookies can be disabled by changing the settings on your browser, though some parts of the website may not function well if you choose to do so.

 

By continuing to use this without changing your browser settings, you agree to our use of cookies as described above.

 

Google Analytics

 

Our website and our mobile application may, from time to time, use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), currently headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted by Google to Google’s location in the US and stored there.

 

In using Google Analytics our website employs the extension “anonymizeIp”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from EU/EEA member states. Google uses this information to analyze your use of our site, to compile reports for us on internet activity and to provide other services relating to our website and our mobile application.

 

Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf. Google states that it will never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

 

You can prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: Google Analytics Opt-out Browser Add-on Download Page. 

 

“Do Not Track” Browser Settings

 

We do not use technology that recognizes a “do-not-track” signal from your web browser, because we do not track users other than for aggregate statistical purposes.

 

How We Retain the Information

 

We will only retain your personal information for as long as necessary for the purposes for which that information was collected as set out in this Privacy Policy or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements. Should you opt out or no longer wish to receive marketing messages from us, we will securely delete your personal information from the relevant mailing list(s).

 

Questions, Comments or Additional Information Regarding Our Privacy Policy

 

If you have any questions or comments in connection with this Privacy Policy, or for further information on our processing activities and your rights in relation to your personal information, please contact our Data Protection Officer at info@servingscore.com. 

 

Notification of Changes

 

We may occasionally update this Privacy Policy as our services and privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, the last update date is posted below, and we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

 

Last updated: April 8, 2024