Effective Date: 29 September 2023
Company: Scube – A Pelican Group Company, the trading name of ACE Software Solutions Inc. (“Company”)

Through this Privacy Policy, we wish to inform you how your personal information is being processed via our website on www.scube.com the “Website”).

Protecting consumer privacy is important to Company. This privacy policy applies only to our Website and outlines how our Website gathers information, how we collect, use, share, secure it and the choices available to you regarding our use of your personal information and how you can access and update this information. This privacy policy also applies to all personal information received by Company from its customers whether in electronic, paper or verbal format.

ACE Software Solutions complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. ACE Software Solutions has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF.

ACE Software Solutions has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

ACE Software Solutions is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF subsequently transfers to a third party acting as an agent on its behalf. ACE Software Solutions complies with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over ACE Software Solutions’ compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF. In certain situations, ACE Software Solutions may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension DPF and the Swiss-U.S. DPF, ACE Software Solutions commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint.  These dispute resolution services are provided at no cost to you.
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For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

1. Information Collection and Use
We collect and process the following kinds of personal information from you:
·         Contact information such as name, email address and phone number;
·         Information about your business such as company name, title, role, the products you are interested in, the corporate events you are interested in and any other details you provide us with.We may use your personal information for the following purposes
:·         We use the personal information you provide us when you contact us, for example in relation to enquiries or comments made by you, for our legitimate interest of communicating with you about our products and services.
·         If you request our services, we use your personal information to establish and fulfil our contract with you. This may include verifying your identity, communicating with you and arranging the provision of our products.
·         We use the personal information you provide us (including your contact details) to send you information on our products and services, special offers and other information based on the interests that you have indicated to us and our understanding of your business needs
.·         We may also use your personal information to do market research, analytics and in pursuance of our legitimate interest of improving our products and services.
·         If necessary, we can use your personal information in order to comply with applicable laws and for our legitimate purpose of protection our legal rights, for example, in connection with legal claims, compliance, regulatory and investigative purposes.If the processing of any personal information is based on consent, you can withdraw your consent for the processing of that data at any time. Consent can be withdrawn by emailing our Customer Support, via available links in our commercial communications (such as newsletters) or by postal mail at the contact information listed below.

The Company does not supplement the personal information it processes with any additional data received from third party sources.

2. Information Sharing
If necessary to perform a service you request from us or to follow-up on your enquiries, we can share your personal information with other Company entities or third-party service providers, for example email and hosting providers, suppliers and sales vendors. Third party service providers will process your personal information on behalf of Company for the purposes above. When we share your data with these parties, we make sure that appropriate safeguards are taken to protect your personal information and to ensure that our service providers are only allowed to use personal information as necessary to provide these services to us. We do not sell your personal information to third parties.

Some Company entities and some partners and service providers are located outside of the European Economic Area, in particular the United States and the countries in which Company has an office. The transfer of data to our Company entities outside of the European Economic Area is protected by EU approved model clauses (read more here). For service providers and third parties outside of the EEA that are not subject to an adequacy decision from the EC (read more here) we also apply the aforementioned EU model clauses. In addition, some of our service providers in the United States are Data Privacy Framework certified (read more here). If you wish to hear more about these safeguards, please contact us through the details further below.We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Links to Third Party Sites
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Our Website includes links to other websites whose privacy practices may differ from those of ours. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

3. User Access and Choice
Upon request, we will provide you with information about whether we hold any of your personal information. You are entitled to ask us for a copy of your personal information, to correct it, erase or restrict its processing, or to ask us to transfer (parts of) this data to other organizations. You also have the right to object to certain processing activities, such as the profiling we may perform for the purposes of direct marketing as described in this privacy policy. Where we have asked for your consent to process your data, you have the right to withdraw this consent, for example by using the opt-out and unsubscribe functionalities in our communications to you. These rights can be limited where we can demonstrate that we have a legal requirement or legitimate ground to process your data.  Under such circumstances we are able to retain your data even if you withdraw your consent. If you want to make use of any of these rights, please contact us by emailing our Customer Support or by postal mail at the contact information listed below or by using unsubscribe mechanism within the email communications that you receive. We will respond to your request to access within 30 days. If you are not satisfied with how we handle such requests or how we otherwise process your personal information, you can lodge a complaint with your local data protection authority.

Retention
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. For example, if you are a customer of Company, Company will keep your personal information for the duration of the contractual relationship you or your company has with us and after the end of that relationship for as long as necessary to perform the purposes set out above or to comply with legal obligations. Personal data we collect as a result of you subscribing to our newsletter or press releases will be stored until you decide to withdraw your subscription.

Email Communications
Receiving emails from our site is part of our service. You will only receive an email from us if you submit a form on the “Contact” page or product pages while downloading brochures or if you send us an email on our email id mentioned on our Website or if you have submitted your business card to us during any conferences or if you are part of the conference where Pelican is also exhibiting.
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If you would like to discontinue receiving this information, you may use the “Unsubscribe” link found in emails we send to you or by emailing our Customer Support.

4. Tracking Technologies
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Passive Collection
As is true of most websites, we gather certain information automatically. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
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Cookies and Other Tracking Technologies
We and our partners use cookies or similar technologies to analyze trends, administer the Website, track users’ movements around the Website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Website or service.
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We partner with third parties who use technologies such as cookies to gather information about your activities on this website which they may use in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here  or here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
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5. Security
Company takes appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Website, you can contact us by emailing our Customer Support.

6. Changes to This Policy‍
This privacy policy was last revised on 29 September 2023. We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
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7. Contact Us
If you have any questions or concerns about this Privacy Policy, contact us below. We will respond to you within 30 days.

Scube (PelicanPay)
53 St Georges Road
London, SW19 4EA
UK
‍privacy@scube.com
Tel +44 20 8947 7200