Privacy Policy
‍Last modified: May 2023
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INTRODUCTION
‍ScaleFi LLC, (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the https://scalefi.io website (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On this Website.
- In email, text, and other electronic messages between you and this Website.
- It does not apply to information collected by us offline or through any other means, including on any other website operated by Company or any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.
- Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website.

By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
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CHILDREN UNDER THE AGE OF 13
‍Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at platform@scalefi.io.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
‍We collect several types of information from and about users of our Website, including information:
- by which you may be personally identified, such as name, postal address, e-mail address, birth date, telephone number, and any other identifier by which you may be contacted online or offline (“personal information”);
- that is about you but individually does not identify you; and/or about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and web beacons.
- From third parties, for example, our business partners.

THE INFORMATION WE COLLECT ON OR THROUGH OUR WEBSITE
‍We may also collection information on or through the Website, as follows:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or posting material. We may also ask you for information when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
‍As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
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THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
‍Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
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HOW WE USE YOUR INFORMATION
‍We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To register and monitor your account.
- To protect against error, fraud, unauthorized transactions, claims, and other liabilities.
- To manage exposure to risk from unauthorized users.
- To provide customer service when you need help.
- To provide status updates on any orders.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including -for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide through it.
- To identify, investigate and fix technical issues with the software running our website.
- To improve our website and services.
- To send you email updates, newsletters, promotions, surveys, and direct mailings.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.For more information, see Choices About How We Use and Disclose Your Information.

DISCLOSURE OF YOUR INFORMATION
‍We may disclose de-identified, aggregated information about our users without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:
- To our subsidiaries and affiliates, if any.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ScaleFi’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ScaleFi about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.

We may also disclose your personal information:- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ScaleFi, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
‍We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Promotional Offers from the Company. If you do not wish to have your information used by the Company to promote our own or third parties’ products or services, you can opt-out by email. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
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ACCESSING AND CORRECTING YOUR INFORMATION
‍You may also send us an email at platform@scalefi.io to request the following:
- Delete Data: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you).
- Change or Correct Data: If you have created an account on our website, you can edit some of your personal information through the customer Dashboard. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., your personal information is inaccurate or unlawfully held).
- Right to Access and/or Take Your Data. You may contact ScaleFi’s Data Protection Officer at platform@scalefi.io request a copy of your personal information and can ask for a copy of personal information to be provided in machine readable form.
- You can also ask to review any of the information that we have retained, how we have used it, and to whom we have disclosed it at any time by contacting us.We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

GENERAL DATA PROTECTION REGULATION (GDPR)
‍References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European Union data protection legislation, including, but not limited to General Data Protection Regulation (“GDPR”). When we process data outside of the European Union or transfer personal information originating from the European Union to other countries not deemed adequate under applicable data protection law, we rely on legally-provided mechanisms to transfer data across borders because countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country. In this regard, we will continue to use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the European Union, which remain an approved method of transferring data of outside of the European Union under GDPR. You may request a copy of the standard contractual clauses by contacting us at platform@scalefi.io.For purposes of GDPR, ScaleFi is the controller of your personal information. See the Contact Information section below for contact details.

DATA RETENTION AND ACCOUNT CLOSURE
‍If you wish to close your account, we will keep some of your data even after you close your account. We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed, but will destroy your personal data when it is no longer needed for the foregoing purposes, or we remove your personal information to render it anonymous.

YOUR CALIFORNIA PRIVACY RIGHTS
‍California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to platform@scalefi.io or write to us at 626 Turquoise Drive, Hercules, CA 94547.

DATA SECURITY
‍We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

CHANGES TO OUR PRIVACY POLICY
‍It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION
‍To ask questions or comment about this privacy policy and our privacy practices, contact us at: platform@scalefi.io