Unscrabble Privacy Terms. Version 1.0 August 2015.

INTRODUCTION

1.1. Purpose

Our mission is to connect the world’s businesses to allow exchange of information between companies for trading purposes and supply chain transparency. Unscrabble is designed to promote economic opportunity for all businesses on our platform by enabling them to connect with, build relationships and exchange information with existing and potential customers.

Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:

We protect your personal information and will only provide it to third parties: (1) with your consent; (2) where it is necessary to carry out your instructions; (3) as reasonably necessary in order to provide our features and functionality to you; (4) when we reasonably believe it is required by law, subpoena or other legal process; or (5) as necessary to enforce our User Agreement or protect the rights, property, or safety of Unscrabble, our Members and Visitors, and the public.

We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.

This Privacy Policy applies to Unscrabble.com and all other Unscrabble websites, apps, developer platforms and other products and services (collectively the “Services”). We may modify this Privacy Policy from time to time, and if we make material changes to it, we will provide notice through our Service, or by other means so that you may review the changes before you continue to use our Services. If you object to any changes, you may close your account. Continuing to use our Services after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.

INFORMATION WE COLLECT

Unscrabble Pty Ltd controls the personal information provided to or collected by our Services.

If you have any concern about providing information to us or having such information displayed on our Services or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a Member, visit our websites, apps or otherwise use our Services. If you have already registered, you can close your account.

We collect your personal information in the following ways:

1.2. Registration

To create an account on Unscrabble, you must provide us with at least your name, email address and/or mobile number, and a password and agree to our User Agreement and this Privacy Policy, which governs how we treat your information. You may provide additional information during the registration flow to help you build your profile. You understand that, by creating an account, we and others will be able to identify you by your Unscrabble profile. We may also ask for your credit card details if you purchase certain additional services.

1.3. Profile Information

After you create an account, you may choose to provide additional information on your Unscrabble profile, such as descriptions of your company capabilities and history. Providing additional information enables you to derive more benefit from our Services by helping you describe your company capabilities; find other customers and suppliers, opportunities, and information; and help other companies and business opportunities find you, follow you and connect with you.

1.4. Customer Service

When you contact our customer support services we may have to access your Unscrabble Mail, and other contributions to our Services and collect the information we need to categorize your question, respond to it, and, if applicable, investigate any breach of our User Agreement or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you.

1.5. Using the Unscrabble Sites and Applications

We collect information when you use (whether as a Member or a Visitor) our websites, applications, our platform technology or other Services. For example, we collect information when you view or click on profiles on our Services, perform a search, initiate and request connections, participate in polls, install one of our mobile applications.

1.6. Cookies

We may use cookies and similar technologies, including mobile application identifiers, to help us recognize you across different Services, learn about your interests both on and off our Services, improve your experience, increase security, measure use and effectiveness of our Services, and serve advertising. You can control cookies through your browser settings and other tools. By visiting our Services, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Policy, which incorporates by reference our Cookie Policy.

1.7. Log Files, IP Addresses, and Information About Your Computer and Mobile Device

When you visit or leave our Services (whether as a Member or Visitor) by clicking a hyperlink or when you view a third-party site, we may automatically receive the URL of the site from which you came or the one to which you are directed. Also, advertisers may receive the URL of the page that you are on when you click an ad on or through our Services. We may also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing Unscrabble using a mobile device), and the name of your ISP or your mobile carrier. Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honour your settings.

1.8. Other

Our Services are a dynamic, innovative environment, which means we are always seeking to improve the Services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information. If we start collecting substantially new types of personal information and materially change how we handle your data, we will modify this Privacy Policy and notify you in accordance with Section 4.3.

HOW WE USE YOUR INFORMATION

2.1. Consent to Unscrabble Processing Information About You

The personal information that you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name may reveal your gender). By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of our User Agreement and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. You can withdraw or modify your consent to our collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your account settings or your profile or by closing your account.

2.2. Communications

We communicate with you through email, notices posted on the Unscrabble websites or apps, messages to your Unscrabble inbox, and other means available through the Services, including mobile text messages and push notifications. You may change your email and contact preferences at any time by signing into your account and changing email settings.

Please be aware that you cannot opt out of receiving service messages from us.

2.3. User Communications

Many communications that you initiate through our Services (for example, an invitation sent to a non-Member) will list your name and primary email address in the header of the message.

Once you have connected with a company, regardless of who sent the invitation, your contact information will be shared with that company

2.4. Service Development; Customized Experience

We use information and content that you and other Members provide to us to conduct research and development for the improvement of our Services in order to provide you and other Members and Visitors with a better, more intuitive experience and drive membership growth and engagement on our Services and to help connect companies to economic opportunity.

We also customize your experience and the experiences of others on our Services. For example, when you sign in to your account, we may display the names and photos of new Companies who have recently joined or recent updates from your connections and companies you follow.

2.5. Polls and Surveys

Polls and Surveys may be conducted by us, Members, or third parties. We or third parties may follow up with you regarding your participation unless you have opted out of receiving messages. You may opt out of participating in surveys by changing your settings to stop receiving these inquiries and requests.

2.6. Search

You can search for information about companies on our Services. For example, you can find companies with particular expertise or experience, operating in certain locations, or Companies that you may know from your industry or profession. We use personal information from our Services, including Member profiles, and Company Pages, to inform and refine our search service.

2.7. Your Content

You should be aware that any information you choose to disclose using these services can be read, collected, and used by other Members, developers, and other third parties. We are not responsible for the information you choose to submit. You can remove your content at any time. However, others may have copied and used the information that you shared.

2.8. Pages for Companies

Certain pages on the Services are public (e.g., company pages), and any communications or information shared through them will be accessible by the entity that created them. If you follow an organization, you will be listed among its followers, which may be viewed by others including the page owner. We use aggregate information about followers and viewers to provide data about such pages’ performance (for example, visits and updates).

2.9. Compliance with Legal Process and Other Disclosures

It is possible that we may need to disclose personal information, profile information, or information about your activities as a Member or Visitor when required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the User Agreement, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) exercise or protect the rights, property, or safety of Unscrabble, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. In light of our principles, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but do not commit to challenge every demand.

2.10. Disclosures to Others as the Result of a Change in Control or Sale of Unscrabble Pty Ltd

We may also disclose your personal information to a third party as part of a sale of the assets of Unscrabble, a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for any of these events. Any third party to which we transfers or sells our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

2.11. Service Providers

We may employ third party companies and individuals to facilitate our Services (e.g. maintenance, analysis, audit, marketing and development). These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to Unscrabble not to disclose or use it for other purposes.

2.12. Data Processing Outside Your Country

We may transfer your information and process it outside your country of residence, wherever Unscrabble, its affiliates and service providers operate.

YOUR CHOICES & OBLIGATIONS

3.1. Rights to Access, Correct, or Delete Your Information, and Closing Your Account

You have a right to (1) access, modify, correct, or delete your personal information controlled by Unscrabble regarding your profile, (2) change or remove your content, (3) de-activate or suspend your account, and (4) close your account.

If you de-activate or suspend your account, your information will remain but your account will be frozen from certain activities (such as making connections). Your company basic profile will still be able to be found and viewed by other users on the system.

If you close your account, your information will generally be removed from the Service.

Please note: Information you have shared with others or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. In addition, you may not be able to access, correct, or eliminate any information about you that other Members copied or exported out of our Services, because this information may not be in our control. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

3.2. Data Retention

We retain the information you provide while your account is in existence or as needed to provide you services. We may retain your information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Privacy Policy and our User Agreement. We may retain information, for a limited period of time, if requested by law enforcement. Our Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only.

We may retain of non-identifying information to retain the integrity of the supply chain transparency and mappings of connections (e.g. a placeholder entity where your company previously sat). This is to allow your connections to understand the effect of your removal from the system so they may take actions to close the gap and address risks in their supply chain. Active connections will be notified that you are no longer active in the system.

IMPORTANT INFORMATION

4.1. Registered Company

Primary entities on Unscrabble are companies. All companies but be officially registered as indicated by relevant business registration numbers (eg in Australia must have a valid ABN or ACN). Unscrabble verifies this information with the relevant business registry before establishing your account.

Is a company becomes unregistered whilst a member of Unscrabble, the account will be suspended or de-activated.

4.2. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the Services or by some other means, such as email. Please review the changes carefully. If you agree to the changes, simply continue to use our Services. If you object to any of the changes to our terms and you no longer wish to use our Services, you may close your account(s). Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Using our Services after a notice of changes has been communicated to you or published on our Services shall constitute consent to the changed terms or practices.

4.3. Direct Marketing

We currently do not share any personal information with third parties for their direct marketing purposes.

We take privacy and security seriously.

4.4. Security

We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your data on our Services is password-protected, and data such as credit card information is protected by SSL encryption when it is exchanged between your web browser and the Services.

However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Members are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.