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PRIVACY NOTICE
Last updated April 15, 2024
This privacy notice for SCB Advisory LLC (also referred to as “we”, “us” and “our”) describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
• Visit our website at https://www.scbadvisory.com
• Engage with us in other related ways, including any sales, marketing, or events.
This privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices related to data privacy, you should not use our website or services. By using the website site or our services, you signify that you agree to be bound by the terms as described in this privacy notice. If you still have any questions or concerns, please contact us at info@scbadvisory.com.
1. Information we collect.
We collect information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities related to our Services, or otherwise when you contact us. The personal information we collect will depend on the context of your interactions with us and the Services you use. The personal information we might collect may include the following:
• names
• job titles
• mailing addresses
• email addresses
• phone numbers
We do not process sensitive information on our website. We rely on the information you provide to us being true, complete, and accurate. We also require you to notify us of any changes to personal information.
2. How we use your information?
We may use your personal information for different reasons when you interact with us. We may use your information in some of the following ways.
3. What Legal Basis we rely on to process your information?
We only use and process your personal information that you have given us permission to use (e.g. consent) for a specific purpose when its necessary and we have a valid legal reason to do so under applicable law such as to inform you about our services, carry out services, fulfill our contractual obligations and other legitimate business interests, to protect your rights or vital interests or to comply with laws and any legal obligations. You can withdraw your consent at any time.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• For investigations and fraud detection and prevention.
• For business transactions provided certain conditions are met.
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
• For identifying injured, ill, or deceased persons and communicating with next of kin.
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
• If the collection is solely for journalistic, artistic, or literary purposes.
• If the information is publicly available and is specified by the regulations.
4. When and with whom do we share your personal information?
We may share information in specific circumstances as described herein or with the following third parties.
Business Transfers - We may share or transfer your information in connection with a negotiation of any merger, sales of the company, financing or acquisition of all or a portion of our company to another company.
Business Partners – We may share your information with business partners in order to offer you certain services or marketing promotions.
5. Cookies and other tracking technologies
We may use cookies and similar tracking technologies like web beacons and pixels to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
We use three main “identifiers” on our website and in our services: cookies, web beacons, and scripts.
We manage some identifiers directly. Other identifiers are managed by third parties. For example, we may use third party IT services to monitor website performance and visitor engagement.
We use identifiers to measure website performance, provide improved services, and deliver personalized advertising. Examples of how we use identifiers include, but are not limited to:
6. How long do we keep your information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to keep your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. How do we keep your information safe?
We have implemented appropriate and reasonable technical security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
8. Do we collect information from minors?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@scbadvisory.com.
9. What are your privacy rights?
In some regions like the EEA, UK, Switzerland, and Canada, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section below.
We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your member state data protection authority.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the notice below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the notice below. You will then be removed from the marketing lists. However, we may still communicate with you for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services.
If you have questions or comments about your privacy rights, you may email us at info@scbadvisory.com.
10. Controls for do-not-track features.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. United States residents privacy rights.
If you are a resident of California, Virginia, Utah, Connecticut, or Colorado, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We may have collected the following categories of personal information about customers and users of our website in the past twelve (12) months depending on services used and how you interact with us:
Categories and 3rd Parties information may be shared
A. Identifiers: contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
3rd Parties: IT service providers, outsourced service providers, your representatives
B. Personal information as defined in the California Customer Records statute: name, contact information, education, employment, employment history, and financial information.
3rd Parties: IT service providers, credit reporting agencies, outsourced service providers, your representatives
C. Commercial information: transaction information, purchase history, financial details, and payment information.
3rd Parties: IT service providers, credit reporting agencies, outsourced service providers, your representatives
D. Internet or other similar network activity: browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
3rd Parties: IT service providers.
E. Geolocation data: device location.
3rd Parties: IT service providers.
F. Audio, electronic, visual, thermal, olfactory, or similar information: images and audio, video or call recordings created in connection with our business activities.
3rd Parties: IT service providers, marketing event, outsourced service providers, your representatives
G. Professional or employment-related information: business contact details in-order-to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
H. Inferences drawn from collected personal information: inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
3rd Parties: IT service providers,
We will use and retain the collected personal information as needed to provide Services for as long as the user has an account with us. To the extent permissible by law we may also use the personal information for marketing new services. You can opt out of receiving marketing information at any time as further explained below.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
• Facilitation in the delivery of our Services and to respond to your inquiries.
• Receiving help through a customer support channel.
• Participation in customer surveys or feedback request.
How do we use and share your personal information?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
California residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
• whether we collect and use your personal information.
• the categories of personal information that we collect.
• the purposes for which the collected personal information is used.
• whether we sell or share personal information to third parties.
• the categories of personal information that we sold, shared, or disclosed for a business purpose.
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose.
• the business or commercial purpose for collecting, selling, or sharing personal information.
• the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
• We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.
The following section applies to residents of Colorado, Connecticut, Utah, and Virginia which have rights further defined under local Data Privacy Acts.
For residents of the above states you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
• Right to be informed whether or not we are processing your personal data.
• Right to access your personal data.
• Right to correct inaccuracies in your personal data.
• Right to request deletion of your personal data.
• Right to obtain a copy of the personal data you previously shared with us.
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").
To submit a request to exercise these rights described above, please email info@scbadvisory.com or visit www.scbadvisory.com and contact us. If we decline to take action regarding your request and you wish to appeal our decision, please email us at the above email address. Within sixty (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision.
Exercise your rights provided under the Privacy Acts
You may contact us by email at info@scbadvisory.com or visit www.scbadvisory.com to contact us.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary in which case we will inform you along with the reason for the extension.
Right to appeal
If we decline to take any action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at info@scbadvisory.com. You review your appeal and respond within forty-five (45) days of receipt of an appeal and inform you of any action taken or not with a written explanation of the reasons for the decision. You may also contact your local Privacy Authority to submit a complaint.
12. Australia and New Zealand residents
You may have additional rights based on the country you reside in.
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information. If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
▪ offer you the products or services that you want
▪ respond to or help with your requests
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the notice.
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian or New Zealand Privacy Principles to the
Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
13. Updates to this notice.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. Contact us about this notice.
If you have questions or comments about this notice, you may email us at info@scbadvisory.com or contact us by post at:
SCB Advisory LLC
4712 E.2nd Street, #620
Long Beach, CA 90803
United States
15. Review, update or delete the data we collect from you.
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit contact us at info@scbadvisory.com.
Copyright © 2024 SCB Advisory LLC - All Rights Reserved.
Email: info@scbadvisory.com