Last Update: December 12, 2023
This Privacy Policy (“Policy”) describes the privacy practices for our website, applications, APIs, and other services accessible via www.screenlake.com and any subdomains thereof, or any services, content or functionality offered on or through any of the foregoing and any subdomains (collectively the “Site”). This Policy is a legal statement that explains how Screenlake, Inc. (“Screenlake”,“we”, or “us”) may collect information from you, how we may use, maintain, protect, and share your information, and how you can control your information.
This Privacy Policy is incorporated by reference into our Terms of Service (the “Terms”). Before you use the Site, please read this Policy and the Terms carefully so you understand our policies and how we process your information. By accessing or using the Site or by accepting (including by clicking to accept or agree when the option is made available to you) any Terms that incorporate this Policy, you accept and agree to be bound and abide by this Privacy Policy and the Terms. If you do not agree with any terms of this Policy or the Terms, you may not access or use the Site for any purpose.
We are committed to protecting your privacy. If you have any questions, comments, or concerns about your information, this Policy, your privacy, or any of our privacy practices, please contact our Data Protection Officer by email at info@screenlake.com or by mailing correspondence to Data Protection Officer at Screenlake, 254 Chapman Rd, 208,#7499, Newark DE, 19702.
When you accessor use the Site, we may collect the following personal information (also known as personal data or PII) (“Personal Information”):
We may also collect information on how the Site is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (“IP address”), user agent, browser type, browser version, operating system, the pages of our Site that you visit, search queries you perform, information you may post to the Site, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, and configuration input provided using the Site’s forms, such as keywords, categories, and search terms.
In some cases, during prospect and customer engagements, or when interviewing applicants for employment, we may record our meetings. These recordings are used for internal educational purposes only and are only captured with explicit consent at the initiation of recording.
Subject to our Terms, if you elect, we may use App Platform Accounts that you connect to the Site to power various features of the Site. If you no longer want any such App Platform Accounts connected to the Site, you can remove the connections from the settings section of your User Account
We may receive and process employment-related information, such as employment history, resumes, background information, recordings of interviews, and other relevant information to help us to recruit new employees and independent contractors, and to manage our interactions with current employees and independent contractors.
We may also use device identifiers, local storage, html modifiers, and different types of caching to help us understand the devices and users who access the Site. Those methods include device identifiers that are either hardware-based or software-based, persistent or non-persistent, and which may identify either a device or a software module within a device (such as a web browser).
We adhere to the standards set out in this Policy and do not monitor or respond to Do Not Track browser requests.
At times, you may request assistance with the Site, report an error or bug on the Site, ask questions about your subscription or account, complete a survey, respond to a questionnaire, or otherwise interact with us regarding the Site, and in the process, you may provide information to us through forms on the Site or through electronic channels such as email. We may request additional information related to any requests or submissions you make.
We do business with (and aim to do business with) many companies whose employees give us their contact information for communication regarding the Site or services we receive from those businesses. We never sell your Personal Information and only use it for purposes of communicating with those businesses. We may use that Personal Information for our own internal purposes to help us improve our business relations processes and practices. We may keep and process the Personal Information after the relationship ends with those businesses when we are required to do so by applicable law or to preserve legal claims that may arise.
We are committed to protecting child privacy. The Site is not intended for children and we do not intentionally or knowingly collect information, personal or otherwise, about individuals under the age of 18, much less children under 13 years old. If you are aware of anyone under 18 using the Site, please contact us using the contact information provided above and we will take required steps to delete any such information and/or prevent that individual from accessing the Site.
We never intentionally receive or process information regarding your sexual orientation, ethnicity, religious affiliation, refugee status, health, or personal finances.
Personal Information does not include anonymized data, which is data that has been rendered anonymous in such a way that you are no longer identifiable(“Anonymized Data”). We may use anonymized data for our own purposes in any manner and without attribution or compensation to any person.
We may use Personal Information for the following reasons:
Use for new purposes. We may use your Personal Information for reasons not described in this Privacy Policy when permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the applicable legal basis.
If you are from the European Economic Area (“EEA”) or the United Kingdom (“UK”), our legal basis under the General Data Protection Regulation for collecting and using the Personal Information described in this Policy depends on the Personal Information we collect and the specific context in which we collect it. We may process your Personal Information because:
We may share Personal Information with third parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection. Such sharing may include:
Without limiting the foregoing, in our sole discretion, we may share Anonymized Data or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your Personal Information, please see the Your data protection rights and choices section below.
In this section, we describe the rights and choices available to all users. Users located in the EEA, UK, Switzerland, and various US states can find additional information about their rights below in the section entitled accordingly.
If you are a resident of the EEA, UK, or Switzerland, you may have certain data protection rights including:
Contact our Data Protection Officer using the contact information provided above to exercise any of your privacy rights. We commit to grant them within 30 daysafter receipt or less. We may require you to prove your identity in some cases to ensure the rights of third parties are not violated by your request.
Please keep in mind that in the case of a vague request we may engage the individual in a dialogue to better understand the motivation and context of the request. We reserve the right to reject requests that are unduly burdensome or repetitive in nature, or if there are legal obligations to maintain the data due to a dispute, compliance, audit, or other investigation.
Notification requirements. We commit to notify you and the applicable data protection authority of breaches of your Personal Information within the timeframe required by law.
Data Protection Authorities. Subject to applicable laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities that you believe are not compliant with applicable law.
Cross-Border Data Transfers. If we transfer your Personal Information from the EEA or UK to another country that is not deemed by the European Commission and/or UK Government, as applicable, to provide an adequate level of protection for Personal Information, the transfer will be performed subject to appropriate safeguards and otherwise in accordance with applicable European data protection legislation. For example, we may use specific appropriate safeguards, which are designed to give Personal Information effectively the same protection it has in Europe – such as standard-form contracts approved by relevant authorities for this purpose. Please contact us for further information about any such transfers or the specific safeguards applied.
If you are a California resident, Under the California Consumer Privacy Act (“CCPA’’) you may have certain rights with respect to the Personal Information that we may have collected about you. These rights may include the following:
Please note that your rights to have Personal Information deleted are subject to several exceptions, specifically the Personal Information that is necessary for us to:
You may read more about your California privacy rights here.
Contact our Data Protection Officer using the contact information in the Contact information section above to exercise any of your privacy rights. We commit to respond to your request within 30 days after receipt or less. We may require you to prove your identity in some cases as noted in further detail below. This is made to ensure that no rights of third parties are violated by your request.
Please keep in mind that in the case of a vague request we may engage in a dialogue so as to better understand the motivation and content of the request. We reserve the right to reject requests that are unduly burdensome or repetitive in nature, or if there are legal obligations to maintain the data due to a dispute, compliance, audit, or other investigation.
To verify your identity, we may require receipt of an email from an account that matches the email we have on record for you (if one exists), authentication into an online account with us (if you have one), information that we match against information we maintain about you, government identification, a declaration under penalty of perjury or other information, where permitted by law. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request.
As summarized in detail in the Personal Information we collect section above, depending on our relationship, we may collect:
The basis for the collection of Personal Information and the manner in which Personal Information is used is outlined elsewhere in this document.
We may share your Personal Information under the circumstances outlined in the How we share Personal Information section above.
Like many companies, we use services that help deliver interest-based ads to you as described in the Marketing and Advertising section above. Our use of some of these services may be classified under California law as a “selling” or “sharing” your Personal Information (including your business and personal contact information, device data, and online activity data described above in “Personal information we collect” section above) with the advertising partners that provide the services. You can submit requests to opt-out of this “selling” or “sharing” as noted above. We have no actual knowledge that we have sold or shared the Personal Information of any California residents under the age of 18.
Anonymized Data, which cannot be re-identified and does not identify you or any individual person, is exempted under the CCPA (e.g., see Section 1798.145. Exemptions) and may be shared with third parties or provided for sale as summarized in the Anonymized Data section above.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about businesses’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We do not participate in the sharing of your Personal Information with third parties for the third parties’ direct marketing purposes, so there is no need to opt-out.
Various other states, including but not limited to, Colorado, Connecticut, Virginia, and Utah, have passed laws providing their state residents rights that are the same or similar to those afforded under the CCPA and the GDPR. These rights, which we honor in the same fashion as outlined above, include without limitation rights to:
Some states also provide their state residents with rights to:
Outside of the US, if you are a resident of another country, state, or province with applicable data privacy laws and regulations that afford you with privacy rights similar to those afforded by the GDPR, CCPA, or other similar laws or regulations, we will honor any requests from you to exercise those privacy rights in accordance with those data privacy laws and regulations to the extent possible.
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us using the information in the Contact information section above. Note that you may continue to receive service-related and other non-marketing emails.
We need to collect certain Personal Information to provide the Site. If you do not provide the Personal Information we identify as required or mandatory, we may not be able to provide the Site.
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We store some information indefinitely for operational purposes, such as technical support and abuse prevention. Other data such as web server logs or store sales reports are only kept as long as space is available for them. Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.
The retention period is determined by various criteria such as the type of user, the services to which you subscribe, and the nature of our relationship. The retention period can be lengthened or shortened based on the cancellation or re-enrollment in our Site. The retention period can also be modified based on internal changes in auditing requirements and/or mandatory retention periods provided by law and statute of limitations.
Your information, including Personal Information, may be transferred to andmaintained on computers located outside of your state, province, country orother governmental jurisdiction where the data protection laws may differ fromthose from your jurisdiction.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
In our continuing efforts to provide our Site in a manner that is convenient and helpful to a growing number of customers, we use the services of service providers (“Service Providers”) to help us host and secure the Site, perform Site-related services, analyze how the Site is used, and manage our business. These services, which include but are not limited to companies that provide cloud services, infrastructure, analytics services, and software to help us host and maintain the Site, and manage our business and customer relationships, may process Personal Information. We take commercially reasonable steps to ensure that these Service Providers are secure and, do not sell or disclose the Personal Information to other parties, or use Personal Information for any purposes other than the services they are providing to us.
GOOGLE ANALYTICS
Please note that we use Google Analytics to assess how users are interacting with the site. The privacy practices of Google Analytics are available atwww.google.com/policies/privacy/partners/ and you may opt out of the use of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
RECRUITING PROVIDERS
We use the services of third parties to help us to recruit new employees and independent contractors and to manage our interactions with current employees and independent contractors. We do our best to contractually ensure that these third-party service providers comply with the policies we have adopted. However, we can’t guarantee their compliance in every case. We only use employment Personal Information for the direct purpose of the employment or independent contractor relationship, and we cease using it as soon as that relationship ends. However, we may keep and process that Personal Information after the relationship ends when we are required to do so by applicable law or to preserve legal claims that may arise.
The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. Unfortunately, as the Internet is not 100% secure, and we cannot ensure or warrant the security of any Personal Information transmitted via the Internet.
You may be able to access third-party websites and other tools, services, or products via our Site, a link, or via our other tools. The privacy policies of these third parties are not under our control and may differ from ours. The use of any Personal Information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any offering, site or other products and services used in connection with the Site. The inclusion of functionality or a link does not imply endorsement of the linked site or service by us or by our affiliates.
We reserve the right to change this Privacy Policy at any time. Any change to this Privacy Policy will become effective on the date it is posted. We recommend that you retain a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Site signifies your acceptance of any changes.
This policy was last updated on December 12, 2023.