Privacy Policy

EFFECTIVE DATE: December 15, 2023

  1. About Scienz AI, LLC

ScienzAI, LLC, and its affiliates (collectively “SAI”, “we”, “us”, or “our”) provide products and services for the B2B market that help sales and marketing organizations be successful.  

  1. Commitment to Privacy 

SAI respects privacy and are committed to protecting personal information, or information identifying a natural person (“Personal Data”).  In this Privacy Policy (“Policy”), we describe the types of Personal Data we collect; why we collect it; the lawful bases for doing so; how we collect Personal Data, use Personal Data, and disclose Personal Data; and any of your rights, including access to your Personal Data.

  1. Application of This Policy

This Policy applies to the Personal Data we collect when you purchase or use any of our Products and Services, including visits to our websites at pureincubation.com and scienzai.com (“Website”).

This Policy also applies to Business Contact Information (“BCI”) that is readily available in the public domain, such as business name, first and last name, business telephone number, job titles, work e-mail addresses and location in which a business is located and an individual works.  BCI information is collected and maintained in our B2B database.  

By purchasing or using our Products and Services, or reading this Policy, you agree that your Personal Data will be handled as described in this Policy. Your purchase or use of the Products and Services, and any dispute over privacy, is subject to this Policy and our applicable Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

By purchasing or using our Products and Services, or reading this Policy, you are deemed to have agreed to the provisions of this Policy, unless you are in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, in which case you are acknowledging that you have been provided this Policy. Without prejudice to your rights under applicable laws, this Policy is not contractual and does not form a part of your contract with SAI or its affiliates or subsidiaries.

In addition, this Policy applies to Personal Data we collect or use about job applicants or employees who are California residents (“Job Applicant and Employee Data”). We collect, use, and disclose Job Applicant and Employee Data for different reasons than other Personal Data we may collect, use, or disclose. For more information about how we collect, use, or disclose Job Applicant and Employee Data, please scroll down to the section titled “Additional Information for Job Applicants and Employees About the CCPA”. If you would like more information, please contact us using the information in section “Contact Us” below.

  1. What Personal Data Do We Collect About You and Why?

Personal Data, as we use it in this Policy, means information that directly identifies you and therefore, can be associated with you. This includes, but is not limited to, your first and last name, and contact information such as your physical address, email address, Internet Protocol address (“IP address”) and phone number.  Personal Data may also include your professional or employment-related details and details regarding your interaction with our Website or email marketing.

Personal Data We Collect Directly from You.

If you request a whitepaper or other specific content, subscribe to our newsletters, or complete the web form on the Contact Us page, we ask you to fill out a brief form that requests information such as your name, company, title, e-mail address, and telephone, as well as your areas of interest and of course the content of any message to us. Similarly, if you provide comments on any blog or community page we may host, you will need to log in – although, if available, you may do that via your social network account such as Facebook, Twitter, or LinkedIn.

Of course, we collect information from you when you respond to an online or a telemarketing survey.

Our Website may include social media features or widgets, such as the Facebook, YouTube, and Twitter buttons. These features may also collect your IP address, which pages you are visiting on our Website, and may set a cookie (see below) even if you do not ‘click’ on the social media widget. These features may also give you the option to post information about your activities on our Website to your social media profile page to share with others within your network. Your interactions with these widgets and any data they may collect even if you do not click on them are governed by the privacy policy of the company providing them.

Personal Data We Receive from Information Readily Available in the Public Domain.

SAI affirmatively collects and receives BCI from various third-party sources, including our partners.  BCI is information pertaining to businesses and individuals that is readily available in the public domain, including but not limited to:  business name, first and last name, business telephone number, job titles, work e-mail addresses and location in which a business is located and an individual works. We collect this information to provide our Products and Services to our customers.

Personal Data We Collect Automatically.

We may automatically collect the following information about your use of our Website through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Website; and the referring Uniform Resource Locator (“URL”), or the webpage that led you to our Website. We also use cookies and other tracking mechanisms in emails that we send you. In the email context, these tools help us know whether you’ve opened our message and whether you have interacted with the content at all. We may combine this information with other information that we have collected about you, including, where applicable, your username, name, and other Personal Data. (Please see below, “Our Use of Cookies and Other Tracking Mechanisms” for more information on these tools). We may also collect information about your interaction with emails sent to you, such as when you open an email sent or click a link included in an email, through technologies such as embedded pixels and link wrappers.  

  1. How We Use Personal Data

We use Personal Data for the following purposes: 

To fulfill or meet the reason you provided the Personal Data. To communicate with you about your purchase or use of our Products and Services, to respond to your inquiries or request for information, and for other marketing and client service purposes.

To tailor the content and information that we may send through development of your profile, to offer content customization, and personalized help and instructions, and to otherwise personalize your experiences while visiting our Website and to help connect you with others who may have Products or Services in which you’ve expressed an interest.

For marketing purposes. For example, we may use your Personal Data, such as your email address or phone number, to send you content, surveys, news and newsletters, or to otherwise contact you about our Products and Services or information we think may interest you. We may also use automatically collected Personal Data to determine whether and how you have interacted with any email messages we have sent you.

To better understand how visitors access and use our Website, both on an aggregated and individualized basis, in order to improve our Website. For testing, research, analysis, and our development of our Products and Services. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Website users is among the assets transferred.

If we would like to use your Personal Data for any purposes other than those described, we will obtain your prior consent unless there are other lawful bases for processing your Personal Data.

  1. How We Disclose Your Personal Data

We may disclose your Personal Data within SAI, and externally with third parties as discussed below.  

When we disclose your Personal Data, we enter into a contractually binding agreement with the recipient of the Personal Data which requires the recipient to comply with the European Union General Data Protection Regulation (“GDPR”), the UK GDPR, the Canadian Personal Data Protection and Electronic Documents Act (“PIPEDA”), as well as any implementing regulation thereof of any jurisdiction, and any applicable data privacy laws and regulations of the United States or any US state, Canada, or any other relevant jurisdictions. 

Internally, Within SAI. We may disclose your Personal Data internally, within SAI. This may involve disclosing your Personal Data outside of the EEA and the UK.  All SAI subsidiaries and affiliates have entered into an intra-company transfer agreement committing to compliance with the GDPR, UK GDPR, PIPEDA, as well all other applicable data privacy laws.  

Other Website Visitors. If you post a comment on the blog pages or any other public area of our Website, your comment and identity will be available to, and searchable by, all users of our Website. This does not apply to any personal data you provide in a Contact Us inquiry.

Upon Your Request or Instruction. When you request content from us or we present you with an online or telemarketing survey, we will typically obtain your direction to disclose limited Personal Data between SAI subsidiaries or affiliates, or specified business customers.

Service Providers. We may disclose the personal data we collect from you to third party vendors, service providers, sub-processors, contractors or agents who perform functions on our behalf. We only disclose Personal Data to our service providers for the purpose of performing services on our behalf. We require that these parties only process the Personal Data for limited and specified purposes consistent with this Policy.

Customers and Partners. We may disclose your Personal Data with our customers and partners under lawful bases, including Consent and/or Legitimate Interest.  We may disclose or make your Personal Data available to partners who provide services on our behalf, such as hosting third-party software we have purchased and integrated into our website.

Business Transfers. If SAI or any of its subsidiaries or affiliates are acquired by or merged with another organization, if substantially all of our assets are transferred to another organization, or as part of a bankruptcy proceeding, we may transfer the personal data we have collected from you to the other organization.

In Response to Legal Process. We also may disclose the Personal Data we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

To Protect Us and Others. We also may disclose the Personal Data we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.

Other Purposes

If we would like to disclose your Personal Data for any purposes other than those described, we will obtain your prior consent, unless there are other lawful bases for processing your Personal Data.

  1. Lawful Bases for Processing Personal Data

We process Personal Data in accordance with all applicable data privacy laws and regulations.  If you are located in the European Union or Switzerland, the GDPR applies.  

If you are located in the UK, the UK GDPR applies. Under either, there are six lawful bases for processing of Personal Data:

  • Consent. The processing is based on demonstrable, freely given, informed, and revocable consent for specific purposes.
  • Performance of a Contract. The processing is necessary for the performance of a contract.
  • Legal Obligation. The processing is necessary to comply with the law.
  • Vital Interests. The processing is necessary to protect human lives.
  • Public Task. The processing is necessary to perform a task in the public interest.
  • Legitimate Interests. The processing is necessary for our legitimate interests, where those interests do not override the data protection interests, rights, and freedoms of the individuals.

Consent, Performance of a Contract, and Legitimate Interests are the three lawful bases that are most appropriate when we process Personal Data:

Generally, Consent is the most appropriate lawful bases when: Individuals freely consent to our processing of their Personal Data after being fully informed (e.g., specific purposes, right to easily withdraw at any time). 

Generally, Performance of Contract is the most appropriate lawful bases when: Our Products and Services are purchased and used, we need to process Personal Data to fulfill our obligations under the written agreements.   

Generally, Legitimate Interests is the most appropriate lawful bases when:

  • Owing to the nature of our business and the size of our databases, it is impractical for us to contact every individual to obtain his/her consent.
  • The processing we do is unlikely to affect the fundamental rights and freedoms of the individuals whose data we process and make available to our Customers and Partners because:
  1. Under our Business-to-Business (B2B) model, we only process BCI taken from the public domain (e.g., work e-mail addresses);
  2. We provide BCI to help our customers promote their offerings to other businesses (i.e., B2B); 
  3. It is in the interest of the professionals whose BCI we process for us to maintain accurate information so that businesses can better reach the most relevant business contacts, thus promoting the legitimate interests of the individual and our customers; and
  4. You always have the right to opt-out and restrict all further processing of your Personal Data.The controllers of our B2B databases are our subsidiary[ies] Leadiro UK Limited and DS Intelligence LLC.
  5. How Long We Keep Your Personal Data

We typically only retain your Personal Data for the time necessary to realize our legitimate business purposes and to comply with the law.

  1. Our Use of Cookies and Other Tracking Technologies

We and our third-party service providers use cookies and other tracking technologies to track information about your use of our Website. We may combine this information with other Personal Data we collect from you (and our third-party service providers may do so on our behalf).

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

What are Cookies and how do they benefit you?

Cookies are small text files that are placed on your computer or mobile device when you browse websites.

Cookies are not actual programs or software. When you visit a website, it stores a snippet of text from your visit; the next time you visit, this text is retrieved by the website, and it enables the website to recognize you. Cookies can be used differently depending on the actual website visited. Cookies allow websites to store such things as user preferences. You can think of cookies as providing a “memory” for the website, enabling it to recognize a user and respond appropriately. Cookies on our Website do NOT store any personally identifiable information such as names, addresses, email addresses or phone numbers.

For more details see: https://www.allaboutcookies.org/

Our cookies help us:

  • Make our Website work as you would expect
  • Remember your settings during visits
  • Allow you to share pages (names/blog articles) with social networks like Facebook or Twitter
  • Continuously improve our Website for you

We do NOT use cookies to:

  • Directly identify any individual who visits our Website. Any personally identifiable information (e.g., IP addresses and location) is processed anonymously using Google Analytics
  • Collect any sensitive information, without your express permission

What information is kept by the cookie?

A cookie will typically hold:

  • The name of the website that it has come from
  • How long the cookie will stay on your computer or mobile device
  • A value – usually a randomly generated unique number

Granting Us Permission to Use Cookies

If the settings on the browser you are using to view our Website (Internet Explorer, Google Chrome, Mozilla Firefox, etc.) are set up to allow cookies, we take this, and your continued use of our Website, to mean that you accept and consent to our use of cookies. Should you wish to remove or not use cookies from our Website you can disable cookies through ‘Internet Options’ on your browser menu at any time, however, please be aware that doing so will probably mean that our Website may not work as well as you would expect.

Our use of cookies falls into a few categories such as:

  • Website function cookies
  • Social media cookies
  • Third party and advertising cookies
  • Analytics cookies

More about Our Cookies

Website function cookies, such as session or preference cookies:

Session cookies

  • These only last until you close your browser
  • They are not stored on your hard drive
  • They are usually used to track the pages that you visit so that information can be customized for you during that visit

Persistent cookies

  • These are stored on your hard drive until you delete them, or they reach their expiry date
  • These may, for example, be used to remember your preferences when you use our Website

We use cookies to make our Website function including:

  • Holding information once you have logged in to save you from having to re-login each time you visit a different page during your session
  • Once you log off or close the browser the session cookie will be removed

Third-party functions

Our Website, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube or Vimeo video. Disabling these cookies is likely to break the functions offered by these third parties.

Social Media Website Cookies

To facilitate easy sharing or liking of content on social network platforms such Facebook and Twitter, we have included sharing buttons on our Website. The privacy implications on this will vary from social media network to social media network and will be dependent on the privacy settings you have chosen on these networks.

Third Party Analytics: Anonymous Visitor & Behavior Statistics Cookies 

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Website. We use these tools to help us improve our Website, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not disclose your Personal Data to these third parties and we do not receive your personal data from these third parties.  Unless you explicitly give us your information by filling in a form or calling us, all data that analytics programs collect is stored anonymously where we only see totals and not specific individual data. To opt-out of the collection of this demographic information from Google Analytics Demographics and Interest Reporting, you can use the Google Analytics Opt-out Browser Add-on.

Examples include:

  • How visitors reached our Website (e.g., from a search engine, an advertisement, from social media site etc.)
  • The activity of users on our Website such as the number of pages viewed, time spent on individual pages, the pages visitors exit from our Website
  • How often visitors return to our Website
  • Visitor technology used (e.g., browser, operating system, device, etc.)

These statistics help us make our Website as user-friendly as possible, to ensure a good experience for all visitors.

We use:

  • Google Analytics. A program that helps us measure site usage details including the examples above;
  • Website Improvement Cookies. We regularly test new designs or site features on our Website. We do this by showing slightly different versions of our Website to different people and anonymously monitoring how visitors respond to these different versions. Ultimately this helps us to offer you a better website;
  • Google Advertising. Some of our business partners or third parties use cookies or other tracking technologies on our Website, including:
    • Third-party vendors, including Google, show ads on websites on the internet;
    • Third-party vendors, including Google, use cookies to serve ads based on a user’s prior visits to our Website;
  • We have no access to or control over these cookies. Users may opt-out of Google’s use of cookies by visiting the Google advertising opt-out page;
  • We use cookies to understand and save your preferences for future visits and compile aggregate data about website traffic and website interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our Website visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business;
  • You may opt-out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt-out of Google Analytics by visiting the Google Analytics opt-out page.

AdRoll Advertising

As you browse our Website, advertising Cookies will be placed on your computer or mobile device so that we can understand your interests. Our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other websites based on your previous interaction with our Website. The techniques our partners employ do NOT collect personal information such as your name, email address, postal address, or telephone number. You can visit this page to opt-out of AdRoll’s and their partner’s targeted advertising.

Turning Cookies Off

You can switch cookies off by adjusting your internet browser settings to stop accepting cookies. 

Please be aware though that turning off cookies will impair the performance of many websites and not just ours.

Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your website preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

  1. User Generated Content

We invite you to post content on our Website, community pages and provide responses to our blog, including your comments, pictures, and any other information that you would like to be available on our Website. If you post content to our Website, all of the information that you post will be available to all visitors to our Website. If you post your own content on our Website, your posting may become public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

  1. Third-Party Links

Our Website may contain links to third-party websites and social media. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

  1. Security of My Personal Data

We have implemented technical and organizational measures to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

  1. Access to My Personal Data

Consistent with applicable laws or regulations, we make good faith efforts to provide you with access to your Personal Data and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.

Consistent with applicable laws or regulations, you may modify Personal Data that you have submitted, or that we have obtained from other sources by contacting us and requesting a copy of whatever identifiable information you have provided to us. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website for a period of time

  1. What Choices Do I Have Regarding Use of My Personal Data?

We may send periodic solicitations or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Based on the requirements of data privacy laws (e.g., GDPR), it can take up to 30 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any services you have requested or received from us.

  1. Children’s Privacy

Our Website is not intended for children under the age of 16.

We do not knowingly collect information from children.  In the event that we learn that we have collected personal on the Website from a child under age 16, we will delete that information promptly. If you believe that we might have any information from a child under 16, please contact us at dataprivacy@scienzai.com.

  1. Visiting our Website from Outside the United States

If you are visiting our Website from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States, United Kingdom, Ireland, Philippines, New Zealand, Australia and France where our servers are located and our database operates. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your Personal Data is protected regardless of where we hold it.

  1. Visiting our Website from the European Economic Area (EEA) and the United Kingdom (UK)

The Lawful Basis for Processing Personal Data of EEA and UK Residents

When we collect information about you through our Websites, our emails, surveys, and so forth, the lawful basis on which we process your Personal Data is performance of a contract between us, namely, to provide you with the content, to help connect you with relevant vendors, and other information in response to your request.

To the extent that we transfer Personal Data from any legal entity we may have in the EEA or UK to a jurisdiction outside the EEA or UK that has not been adduced by the European Commission as providing adequate data protections, we will ensure that such Personal Data is safeguarded through appropriate contractual terms, and technical and organizational measures.

Rights for EEA and UK Residents

In addition, if you are a resident of the EEA or the UK, you have the right to:

Find out if we use your Personal Data, to access your Personal Data, and receive copies of your Personal Data.

Withdraw any express consent that you have provided to the processing of your Personal Data at any time without penalty.

Access your Personal Data and have it corrected or amended if it is inaccurate or incomplete.

Obtain a transferable copy of some of your Personal Data which can be transferred to another provider when the Personal Data was processed based on your consent.

If you believe your Personal Data is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Data, you also have the right to request that we restrict the processing of your Personal Data pending our investigation and/or verification of your claim. 

Request your Personal Data be deleted or restricted under certain circumstances. For example, if we are processing your Personal Data on the lawful basis of your consent and have no other lawful basis to process such, you may request your personal data be deleted when you withdraw your consent.

If you wish to exercise any of these rights or raise a complaint on how we have handled your Personal Data, please first contact us at the Contact Us details below.  If you wish to make a complaint with a supervisory authority, their contact information may be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en (if in the European Union) or https://ico.org.uk/make-a-complaint/ (if in the UK).

  1. California Residents

California “Shine The Light” law

Pursuant to California’s “Shine The Light” law (California Civil Code § 1798.83), California residents are entitled to request, once a year and free of charge, certain information regarding what types of their Personal Data may be disclosed to third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under this law, a business is to either provide California customers certain information upon request or permit California customers to opt-out of this type of disclosure.  You may request this information by contacting us at dataprivacy@scienzai.com and indicate in the e-mail subject line, “California Shine The Light Request.”  Please include your mailing address, state of residence and e-mail address with your request.

The California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, gives California residents enhanced rights with respect to their Personal Data that is collected by businesses. 

First, California residents may opt-out of having their Personal Data sold to other persons or parties. 

Second, California residents have a right to know:

What specific pieces of information a business has about the resident;

Categories of Personal Data it has collected about the resident;

Categories of sources from which the Personal Data is collected;

Categories of Personal Data that the business sold, shared, or disclosed for a business purpose about the resident;

Categories of third parties to whom the Personal Data was sold, shared, or disclosed for a business purpose; and

The business or commercial purpose for collecting, selling, or sharing Personal Data.

Third, California residents can request that the Personal Data a business has collected from them be deleted from the business’s systems and records, subject to certain exceptions.

Fourth, California residents can request that inaccurate Personal Data a business maintains about them be corrected. 

SAI is covered under the CCPA as we collect and process the Personal Data of California residents.  This Policy provides the required notices to California residents.  The CCPA also prohibits covered businesses from providing discriminatory treatment to California residents if they exercise their rights under the Act.

SAI may sell or share Personal Data of California residents. You can request to opt-out of the sale or sharing of your Personal Data at any time by completing the online form (available at https://scienzai.com/privacy-policy-ccpa/) or by sending us an e-mail at dataprivacy@scienzai.com.  Under the CCPA, we have 15 days after receipt to implement a request to opt-out. The CCPA requires us to state that we do not have actual knowledge that we have sold or shared the Personal Data of California residents under 16 years of age.

To make a “request to know,” “request to delete,” or “request to correct” your Personal Data, send us an e-mail at dataprivacy@scienzai.com . (Please put “Request to Know,” “Request to Delete,” or “Request to Correct” in the subject heading of your email.)  You may also submit these requests via  Do Not Sell My Personal Information or by mailing your request to address in the United States to:

Scienz AI, LLC

Data Protection Officer

222 Rosewood Drive

Danvers, MA 01923

We will honor these requests for individuals in the United States whether or not you would qualify as a California resident under the CCPA.

We will confirm receipt of your request to know, delete, or correct within 10 days along with a description of what steps we will take to verify and respond.  We must provide the requested information or delete your Personal Data within 45 days of receipt of your request but can use an additional 45 days, but we will let you know additional time is needed.

When contacting us, we may ask you to provide certain, limited Personal Data, such as your name, e-mail address and/or username to verify your request and to match with our records and systems.  We will not retain this Personal Data or use it for any other purpose.  Residents of other states may also have similar rights to request information about or delete their Personal Data.  To inquire about exercising these rights, please contact us at dataprivacy@scienzai.com.

Additional Information for Job Applicants and Employees About the CCPA

This subsection contains information about how we may collect, use, and disclose the Personal Data about California residents related to any job application or employment with us. This subsection does not contain information about how we may collect, use, and disclose Personal Data about California residents not related to any job application or employment with us, which is described in the remainder of this Policy.  This subsection does not apply to non-California residents.

For example, if you are a California resident and apply for a job with us through the Careers page on our Website, the Policy outside of this subsection explains how we may collect, use, or disclose the Personal Data we collect or generate about you as you browse or navigate our website. This subsection explains how we may collect, use, or disclose the Personal Data you submit by clicking “Submit Application” on our Website to apply for a job.

In the proceeding 12 months, we may have collected the following categories of information about job applicants and employees who are California residents:

Category of Personal DataExamplesPurpose of Collection and Use
IdentifiersName, address, email address, phone number, social security number, online identifier·      Communicate with job applicants and employees
·      Make employment and compensation decisions
Comply with applicable law
California Consumer Records law informationName, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, other financial information, medical information, health insurance information·      Communicate with job applicants and employees
·      Make employment and compensation decisions
 
·     Provide employee benefits and compensation
Comply with applicable law
Characteristics of protected classifications under California or federal lawGender, race, ethnicity, veteran status, disability status, sexual orientation, national origin, criminal records· Comply with applicable law
Financial informationBank account information· Provide employee benefits and compensation
Internet or other electronic network activityNetwork activity, network connections, IP address· Detect and prevent fraud and malicious activity
· Ensure network and information security and compliance with our IT and data privacy and security policies
· Comply with applicable law
Geolocation informationIP geolocation· Detect and prevent fraud and malicious activity
· Ensure network and information security and compliance with our IT and data privacy security policies
· Comply with applicable law
Audiovisual informationRecording of calls or meetings, headshots, sales presentations· Record keeping of meetings as business records
· Make employment and compensation decisions
Professional or employment-related informationJob titles, compensation, professional experience, employment history, references, education, degrees· Make employment and compensation decisions
Education informationEducational institutions attended, dates of attendance, degrees granted· Make employment and compensation decisions
Inference informationInferences about a job applicant’s or employee’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes· Make employment and compensation decisions
· Comply with applicable law
Sensitive personal information·      Social Security number, driver’s license number, passport number, or state-issued identification card number
·      Racial or ethnic origin
Health information for purposes of ADA reasonable accommodations
· Comply with applicable law

We may have collected Personal Data about job applicants or employees from the following sources:

Category of SourcesCategory of Personal Data about Job Applicants and Employees
Through job applications and the application and hiring process
We may collect Personal Data about job applicants and employees through job applications and related application materials that they submit to us.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Audiovisual information
· Professional or employment-related information · Education information
· Sensitive personal information (racial or ethnic origin, health information)
From employees
We may collect Personal Data from employees as part of the onboarding process and continued employment process. We may also collect additional Personal Data automatically from employees as they use our information and communication systems.
· Identifiers
· California Consumer Records Law information
· Financial information
· Information or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Inference information
· Sensitive personal information (Social Security number, driver’s license number, passport number, or state-issued identification card number, health information)
Third party suppliers
We may collect Personal Data about job applicants or employees through third-party suppliers, which may be Service Providers under the CCPA or not. We use these third-party suppliers to conduct background checks, source application information (such as when an individual applies for a position through LinkedIn), or to identify potential candidates who may be a good fit to work with us (such as outside recruitment agencies)
· Identifiers
· California Consumer Records law information
· Professional or employment-related information
· Education information
· Inference information
Other third parties
We may collect Personal Data about job applicants or employees through other third parties, such as through reference calls during the hiring process or communicating with other entities to track and maintain appropriate records of education, training, and development activities, or from healthcare providers, as necessary to make hiring, employment, and promotion decisions.
· Identifiers
· California Consumer Records law information
· Professional or employment-related information
· Education information
· Inference information

We may have sold Personal Data of California residents within the past 12 months. However, we do not sell or share the Personal Data related to and collected through any job application or employment with us described in this section, and we have not done so in the past 12 months. For more information about how we sell Personal Data of California residents, please navigate in this Policy to the section titled “California Consumer Privacy Act (CCPA)“.

The CCPA requires us to state that we do not have actual knowledge that we have sold or shared Personal Data of job applicants or employees under 16 years of age. We do not have employees under 18 years of age.

We disclose Personal Data of job applicants and employees as follows, and we may have done so in the past 12 months:

Category of Third Party Recipient And Purpose Of DisclosureCategory of Personal Data about Job Applicants and Employees
Service providers
We engage third-party service providers to perform a variety of services on our behalf, which may mean that we have to disclose Personal Data about job applicants and employees to these third parties. For example, we may disclose Personal Data to a payroll provider in order to process payroll, or to a SaaS provider to provide software used by employees to fulfill their job duties and discharge their responsibilities. When we disclose Personal Data in this way, we put in place appropriate measures to make sure that our service providers keep the Personal Data confidential and secure.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Audiovisual information
· Geolocation information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Financial institutions
We may disclose Personal Data about employees to financial institutions in order to pay employee compensation.
· Identifiers
· Financial information
· Professional or employment-related information
Benefit plans
We may disclose Personal Data about employees or their dependents to our benefits providers in order to provide benefits to our employees and their dependents, such as health, dental, and disability insurance.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Inference information
· Sensitive personal information (racial or ethnic origin)
Professional Services Firms
We may disclose Personal Data about job applicants or employees to professional services firms that help us comply with our legal and regulatory obligations and establish, enforce, and otherwise exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Parents, Affiliates, and Subsidiaries
Pure Incubation Ventures, LLC is the parent entity of our group of companies that make up the Pure Incubation Ventures, LLC family. We may disclose Personal Data about job applicants or employees to other companies within the Pure Incubation Ventures, LLC family, in order to make employment or hiring decisions, to provide employ benefits and compensation, or to otherwise manage and operate the Pure Incubation Ventures, LLC family of companies. When we disclose Personal Data about job applicants or employees to other companies within the Pure Incubation Ventures, LLC family, their collection, use, and disclosure of that Personal Data is subject to this Policy.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Government Entities
We may disclose Personal Data about job applicants and employees to Government Entities and law enforcement officials, for various reasons, including as required by law or regulation or to confirm or verify a California resident’s right to work in the United States.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Audiovisual information
· Geolocation information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Merger and Acquisition Activity
We may disclose Personal Data about job applicants or employees to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and performing the proposed transaction.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information

The CCPA requires us to state that we do not use or disclose sensitive personal information about job applicants or employees for purposes other than to perform the services reasonably expected by an average job applicant or employee who applies for a job or is employed by us; to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Data; to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those reasonable for those actions; or to collect or process sensitive personal information where such collection or processing is for the purpose of inferring characteristics about a job applicant.

CCPA Consumer Request Rights Metrics

As described in this Policy, California residents have the opportunity to access, delete, and correct the Personal Data that we maintain about them. SAI presently is compiling metrics required by the CCPA for consumer requests made under the CCPA for calendar year 2022 and will update this Policy to provide those metrics by July 1, 2023.  If you would like information about our metrics for calendar year 2021, please contact us using the information in section 22, “Contact Us”.

  1. Contact Us

If you have questions regarding this Policy, or would like to report a potential privacy or security incident or vulnerability or otherwise make a complaint, please contact us:

Call us at (888) 591-6940; or e-mail us at dataprivacy@scienzai.com; or write us at:

Scienz AI, LLC
Data Protection Officer
222 Rosewood Drive
Danvers, MA 01923

  1. Changes to This Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Website, at scienzai.com

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