Privacy Policy

Scale to Win (“STW,” “we” or “us”) operates scaletowin.com (“Site”) and our Spoke software and service (“Service(s)”). We respect your privacy.

Our policy is simple. We do not sell, rent or share your information. All information regarding visitors to our Website, our customers, our customer’s contacts or other consumers that our customers reach through our Service are treated carefully and as described in this Privacy Policy. By using our Site, you acknowledge and agree to this Privacy Policy as well as our Terms and Conditions.

This Privacy Policy describes the types of personal information we collect on the Site and via our Service, whether online, offline or by contacting us by phone or text, how we may use the information and the purposes for which we may use it, with whom we may share it and the choices available to you. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

This Privacy Policy does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

If you do not agree to this Privacy Policy, please do not use the Site or our Service.

We may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):

Providing the Services;
Our operational purposes;
Auditing consumer interactions on our site;
Detecting, protecting against, and prosecuting security indicents and fraudulent or illegal activity;
Bug detection, error reporting, and activities to maintain the quality or safety of our Service;
Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
Other uses that advance our commercial or economic interests, and
Other uses about which we notify you

Examples of these types of uses are identified below. We may also use the below categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

Categories of Sources	Categories of Personal Information We Collect	Examples of Use	Categories of Third Parties With Which We May Share That Information
Site Visitors	Identifiers (e.g., name, email address, phone numbers, IP address, etc.)	Providing the Site or the Service, including to register an account for you Fixing and improving the Site or the Service Communicating with you, e.g. Site “Contact” page Analyzing use of the Site or the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Site or the Services	Data analytics service provider (see Google Analytics below).
Customers	Identifiers of Customer (e.g., name, email address, phone numbers, etc.) Identifiers of contacts of Customer (e.g., name, phone numbers, etc.) Financial Data	Provide the Services Communicating with you, e.g. payment process Fixing and improving the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Services	Financial Institutions (payment processing)
Customer’s Contacts	Identifiers (e.g., name, phone numbers, etc.) Location Information (general or precise GPS according to permissions)	Providing the Services Communicating with you, e.g. customer support Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Services	None
Consumers reached by our Customers via the Service	Identifiers (e.g., name, phone numbers, etc.) Location Information (general or precise GPS according to permissions)	Providing the Services Communicating with you, e.g. customer support Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Services	Providing the Services Communicating with you, e.g. customer support Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Services

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We do not sell, rent or otherwise share personal information about you, except as described in this Privacy Policy and only for the purposes of providing Services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform Services on our behalf or comply with legal requirements.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content (including advertising) tailored to our users’ interests and the manner in which our users browse our Site, and (iii) managing our business. We also use this information to help diagnose technical and service problems, administer our Site, identify users of our Site, and gather demographic information about our Site visitors and customers. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our Site visitors.

We do not respond to browser-initiated Do Not Track signals, as the internet industry is currently still working on Do Not Track standards, implementations, and solutions.

California Consumer Privacy Act Notice

If you are a California resident, you may request that we:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Service.

If would like to exercise any of these rights, please submit a request at info@scaletowin.com or by calling (888) 365-4993. You will be required to verify your identity before we fulfill your request. To do so, you will need to provide the information identified by us.

California residents may opt out of the “sale” of their personal information. STW does not “sell” your personal information as defined by the California Consumer Privacy Act and its implementing regulations.

Google Analytics

We use Google Analytics, a third-party web analytics service, on our Site. Google Analytics use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Site. The information collected through these means (including IP address) is disclosed to these analytics providers, who use the information to evaluate use of the Site. To learn more about Google Analytics and how to opt out, please visit www.google.com/analytics/learn/privacy.html.

Your Options

We offer you certain choices about how we communicate with you and what information we collect from you.

Visitors to the Site or who contact us offline or by phone or text who do not agree with this Privacy Policy should not use the Site or our Services.

Customers may update their preferences and make choices regarding the maintenance, use or deletion of any information.

Contacts of customers or consumers reached by our customers via the Service may contact us by unsubscribing from the Service by calling (888) 365-4993 or may contact us at info@scaletowin.com, providing us with your relevant contact information (phone number/s) and we will remove your information from our database for a specific customer or all customer per your instructions. We will comply with your requests but you acknowledge and agree that we do not control the collection, storage, use or destruction of your information by our customers.

Shine The Light

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from STW once a year, free of charge, information about their personally identifiable information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year, if at all. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared such information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:

Scale to Win
Attn: Shine The Light Request
13742 Harper StSanta Ana, CA 92703

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. Also note that under California law, businesses are only required to respond to a consumer request once during any calendar year.

Data Protection Laws

Our Website is intended for use by individuals located in the United States. However, some of the personal information we collect about you through the Site may be transferred to countries other than the United States. If you are a user located outside of the United States, you understand and consent to having any information processed in the United States. United States data protection and other relevant laws may not be the same as those in your jurisdiction. This includes the use of cookies and other tracking technologies as described above. As a result, please read this Privacy Policy with care.

Links To Other Websites

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with STW. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with STW, any use of those websites, or the privacy practices of those websites.

How We Protect Personal Information

STW uses administrative, technical and physical security measures to help protect your personal information. And while we have taken reasonable measures to protect your information, please be aware that despite our efforts no security measures are perfect or impenetrable and no data transmission method can be guaranteed against an unauthorized intrusion. Any information disclosed online or via any digital media is vulnerable to intrusion or misuse and as a result we cannot guarantee the complete security of your personal information. We process and store data in the United States and in other locations for back-up and recovery purposes. If you live outside of the United States, you understand and agree that we may transfer your information, including personal information, within the United States. Our Website is subject to U.S. laws, which may not afford the same level of protection as those in your country.

Updates To Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices and applicable law. We suggest that you periodically review the Privacy Policy for amendments.

How To Contact Us

If you have any questions about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at info@scaletowin.com or write to us at:

Scale to Win
Attn: Privacy Policy
13742 Harper St
Santa Ana, CA 92703

This Privacy Policy (“Privacy Policy”) is effective as of August 27, 2020.