Scuba Analytics Privacy Policy

Purpose

In this Website Privacy Statement (“statement”), Scuba Analytics Inc. (“Scuba Analytics”, “Scuba”, “We”, “our” and “us”) provides information about how we collect, use and transfer personally identifiable data from you, an individual person and website visitor, through Scuba Analytics Inc.’s publicly accessible websites (any of our websites such as https://www.scuba.io that can be accessed without a password) and on which we post a direct link to this statement (collectively the “site”).

Scope

This statement covers only data collected through the site and not any other data collection or processing, including, without limitation, data collection practices of webpages to which the site links, or data that we or our affiliates collect offline or through web pages that do not display a direct link to this statement, for example the Salesforce.com applications on which we host data for registered customers like Scuba Analytics Inc.

Types of Data and Collection Methods

Through the site, we receive data that you actively submit as well as data that we track:

Actively Submitted Data: When you request information, subscribe to a mailing list or for a service, respond to an online survey or otherwise actively send us data, we usually collect data such as your name, e-mail address(es), mailing address(es), telephone number(s), and certain information related to the business you represent such as number of employees and industry type. You can opt out of providing information by not entering it when asked and, if such information is required in order to allow us to respond to your inquiry, you will receive a notice advising you of this. In each such instance, you will know what data we collect through the site, because you actively submit it.

Passively Tracked Data: When you visit the site, we also passively track information on your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the site, the Internet address of websites from which you link to our site, the computer technology you are using and your movements and preferences on our site. We use technology that many other websites employ, including, without limitation, “cookies'' or small data files stored on your computer’s hard drive, to collect such information. In some instances, we also use cookies to collect information in connection with future visits from that website, to recognize you as a previous visitor, or to track your activity on our site. If you follow a link to the site from an affiliate or promotion, we store information about your arrival from that affiliate or promotion in a session cookie. You do not need to have cookies turned on to visit our site. You can refuse cookies by turning them off on your browser. But, if you want to access web pages that require registration, you need to accept a mandatory session cookie, which you can delete after you leave the site.

Combinations: Unless you also actively submit personal information such as your name or address, passively tracked data does not typically allow us to identify you personally (even though it can theoretically be done, we do not have the means or an interest to find out who you are, unless you identify yourself voluntarily through an active submission of data). To the extent permitted by applicable law, we reserve the right to combine passively tracked data with personal data that you actively submit.

Collection Purpose, Use of Data

Through the site, we receive data that you actively submit as well as data that we track:

Disclosures of Personal Information

In keeping with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, Scuba may transfer personal information to third parties, including transfers from one country to another. We may share contact information (that we collect through various marketing efforts) with trusted business partners, such as system integrators, distributors and referral partners. We engage agents and service providers who process data only on our behalf and for our purposes under confidentiality agreements or contracts. We require that these third parties maintain the same level of security and privacy protection as Scuba.

Scuba may also share data in the following situations:

Where required to meet a legal obligation, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.
Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.

Opt-Out

In connection with promotions or other projects, we may ask you specifically whether you have objections against a certain kind of data use or sharing. If you opt-out under such circumstances, we will respect your decision. To opt-out of receiving commercial communications from Scuba Analytics Inc. please click on the “opt-out” link in the communication or, please contact us at privacy@scuba.io. Please note that our affiliates and other data recipients have their own data privacy policies, which may differ from ours and you would have to contact them separately with respect to opt-out requests.

Access

If personal information you have submitted through the site is no longer accurate, current, or complete, and you wish to update it, please send an e-mail to privacy@scuba.io. Upon appropriate request we will usually be glad to update or amend your information, but we reserve the right to use information obtained previously to verify your identity or take other actions that we believe are appropriate.

Security

Transmissions over the Internet are never 100% secure or error-free. However, we take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Effective Date, Amendments

This statement is effective as of January 21, 2022. We reserve the right to change, modify, add or remove portions of this statement from time to time and in our sole discretion, but will alert you that changes have been made by indicating on the statement the date it was last updated. When you visit the site, you are accepting the current version of this statement as posted on the site at that time. We recommend that users revisit this statement on occasion to learn of any changes.

Recourse and Privacy Shield Self-Certification

Scuba Analytics complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. Scuba Analytics has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Scuba Analytics recognizes that the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield are no longer valid transfer mechanisms for personal information from the European Union and its Member States, the European Economic Area, or Switzerland. The U.S. Department of Commerce, which oversees compliance with Privacy Shield, has stated that it will nonetheless continue to administer the Privacy Shield program and that participants are not relieved of their obligations under Privacy Shield. Accordingly, Scuba Analytics, as a participant in the Privacy Shield program, will continue to comply with its commitments under the Privacy Shield (as described more fully below) and its robust internal data protection policies. Please see our Privacy Statement or Service Agreements for information on how we protect cross-border transfers of personal information in accordance with applicable legal requirements, including the European Commission approved standard contractual clauses.

Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@scuba.io. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@scuba.io.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Scuba Analytics’ accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Scuba Analytics remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Scuba Analytics proves that it is not responsible for the event giving rise to the damage.

Scuba Analytics’ participation in Privacy Shield is subject to investigation and enforcement by the Federal Trade Commission. In compliance with the Privacy Shield Principles, Scuba Analytics commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Statement should first contact Scuba using the information in the “Contact Us” section below.

In compliance with the Privacy Shield Principles, Scuba Analytics commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Scuba Analytics by email at privacy@scuba.io

Scuba Analytics has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Scuba Analytics agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. Scuba Analytics acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Contact Us

Please feel free to contact us with any comments, questions, complaints or suggestions you might have regarding the information practices described in this statement. You may send us an email at privacy@scuba.io or write to us Scuba Analytics Inc., 800 West El Camino Real, Suite 180 | Mountain View, CA 94040, telephone: +1 844.426.4678.