PRIVACY NOTICE

Revised 10/2024

1. Introduction

SCLogic and all its affiliated companies (here referred to as “SCLogic”) are committed to protecting your privacy and developing technology, systems, and processes that provide a powerful and safe experience with our applications. This Privacy Notice applies to the Intra application (the “App”) and governs data collection and usage. By using the App, you consent to the data practices described in this Statement.

This Privacy Notice refers to personal data/personally identifiable information (here referred to as “personal data”) which is defined as information concerning a living person (here referred to as “you” or “your” or otherwise as a “data subject”).

To the extent that users of the App are residents of the European Union (EU), the United Kingdom (UK), or California, and to the extent that SCLogic provides goods and/or services to such residents and/or collects personal data from them, SCLogic is subject to the provisions of the EU General Data Protection Regulation 2016/679 (“GDPR”), the UK Data Protection Act 2018 (“UK GDPR”), and the California Consumer Privacy Act (“CCPA”), which serve to protect and enhance the rights of data subjects.

SCLogic is also committed to complying with international standards such as ISO/IEC 27001 and ISO/IEC 27701, which relate to information security management and privacy information management, respectively.

2. SCLogic – Who We Are

Founded in 1996, SCLogic is a leading provider of the innovative in-building logistics platform, Intra, that leverages the latest scanning, printing, mobile computing, and wireless technologies. The company has thousands of enterprise, government, and university users around the world. SCLogic is headquartered in Annapolis, MD, with offices in New Jersey, Texas, Florida, Colorado, Illinois, California, and Sweden. For more information about SCLogic, please visit our website www.sclogic.com.

3. Collection of Your Personal Information

SCLogic collects personal data such as your device information, IP address, operating system, usage data, and other technical data. We may request access or permission to certain features from your mobile device, including your camera, to facilitate functionalities such as scanning barcodes, configuring the application via QR codes, and attaching photos to item updates. Camera access is requested but not mandatory. Devices with built-in barcode scanners do not need to enable this permission.

We are committed to respecting and protecting your privacy and want you to feel secure when using our App and providing information to us. To provide you with relevant information, respond to your requests, and enhance your experience on our App, we sometimes request that you provide us with personal data as referred to above.

Where SCLogic transfers personal data from within the EU/UK to the United States or other countries outside the European Economic Area (EEA), it will do so pursuant to mechanisms validated by regulatory requirements of the GDPR and UK GDPR for such international transfers, including but not limited to the use of Standard Contractual Clauses as appropriate.

4. Legal Basis for Processing Personal Data

We process your personal data based on the following legal grounds:

• Consent: When you voluntarily provide personal data by using features of our App that require such data, including granting permissions for access to certain device features.
• Contractual Obligations: When processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
• Legitimate Interests: When processing is necessary for our legitimate interests in operating our App, providing services, improving our offerings, and ensuring network security, provided that your interests and fundamental rights do not override those interests.

5. Obligation to Provide Personal Data

Providing your personal data is optional. However, certain features of our App may not be available if you choose not to provide the necessary information or permissions (e.g., access to the camera for scanning barcodes).

6. Consent

By agreeing to this Privacy Notice, you are consenting to SCLogic processing your personal data for the purposes mentioned in this Privacy Notice. You have the right to withdraw your consent at any time by contacting us at [email protected] or 1.888.700.7027.

7. Personal Information You Choose to Provide

To provide the best experience when you use our App, we may ask you for personal data. Below are some ways you may provide personal data to us:

• Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s camera and other features. Camera access is requested but not mandatory. The App uses the camera for the following purposes:

• To facilitate configuring the application via QR codes.
• To allow you to take photos and attach those photos to item updates.
• To allow you to scan barcodes using the camera. Devices with built-in barcode scanners do not need to enable this permission.

If you wish to change our access or permissions, you may do so in your device’s settings.

• Mobile Device Data

We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information, and IP address.

8. Use of Cookies and Tracking Technologies

The App may use “cookies” and similar technologies to personalize your experience. A cookie is a small data file stored on your device that helps us understand how you use the App and how we can improve it. You have the ability to accept or decline cookies. If you choose to decline cookies, some interactive features of the App may not function properly.

9. How We Use the Information We Gather

We use your personal data to:

• Operate and improve our App and services.
• Deliver the services you have requested.
• Respond to your inquiries and fulfill your requests.
• Provide you with information about other products or services that may interest you.
• Conduct research and analysis to enhance our offerings.
• Customize your experience on our App.

We also collect information about your device hardware and software automatically, such as your IP address, operating system, device type, and usage patterns. This information is used for the operation and quality maintenance of the service, and to provide general statistics regarding use of the App.

10. Use of Your Personal Information

SCLogic collects and uses your personal data to operate the App and deliver the services you have requested. We may also use your personal data to inform you of other products or services available from SCLogic and its affiliates. We may contact you to conduct surveys to research your opinion of current services or potential new services.

SCLogic does not sell, rent, or lease its customer lists to third parties. We may share data with trusted partners to help us perform statistical analysis, send you communications, provide customer support, or arrange for deliveries. All such third parties are required to maintain the confidentiality of your information and are prohibited from using your personal data except to provide these services to SCLogic.

SCLogic does not use or disclose sensitive personal data such as race, religion, or political affiliations without your explicit consent.

We keep track of the features and pages our users visit within the App to determine what services are most popular. This data is used to deliver customized content and advertising to users whose behavior indicates an interest in particular subject areas.

SCLogic will disclose your personal data without notice only if required to do so by law or in the good faith belief that such action is necessary to:

• a) Conform to legal requirements or comply with legal process served on SCLogic.
• b) Protect and defend the rights or property of SCLogic.
• c) Act under exigent circumstances to protect the personal safety of users of SCLogic or the public

1. 11. Your Rights as a Data Subject

Under the GDPR and UK GDPR, you have the following rights regarding your personal data:

1. 1. • Right of Access: You have the right to request a copy of the information we hold about you.
      • Right to Rectification: You have the right to correct data that is inaccurate or incomplete.
      • Right to Erasure: You have the right to request that we erase your personal data under certain conditions.
      • Right to Restrict Processing: You have the right to restrict the processing of your personal data under certain conditions.
      • Right to Data Portability: You have the right to have the data we hold about you transferred to another organization.
      • Right to Object: You have the right to object to certain types of processing, such as direct marketing.
      • Rights Related to Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing.

To exercise any of these rights, please contact us at [email protected] or 1.888.700.7027. We may request additional information to confirm your identity.

1. 1. 12. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.

1. 1. 13. Right to Withdraw Consent

If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. To withdraw consent, please contact us at [email protected] or follow the instructions in our communications.

1. 1. 14. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with:

• For EU residents: Your local data protection authority in the EU.
• For UK residents: The Information Commissioner’s Office (ICO) in the UK.

1. 1. 15. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

1. 1. 16. International Data Transfers

Your personal data may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

We have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data between our group companies and with our third-party service providers and partners.

1. 1. 17. Security of Your Personal Information

SCLogic implements appropriate technical and organizational measures to secure your personal data from unauthorized access, use, or disclosure. We store the personal data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. When personal data is transmitted to other systems, it is protected through encryption.

However, you should always take into consideration that the Internet is an open forum, and that data may flow across networks with little or no security measures and therefore we cannot guarantee that such information may not be accessed by people other than those you intended to access it.

1. 1. 18. Data Breach Notification

In the unlikely event of a data breach affecting your personal data, we will notify you and the relevant supervisory authorities as required by applicable laws.

1. 1. 19. Third-Party Processors and Sharing

We may employ third-party companies and individuals to facilitate our services (“Service Providers”), provide services on our behalf, perform service-related tasks, or assist us in analyzing how our services are used. These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

1. 1. 20. Children’s Privacy

Our App is not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16. If you are under 16, please do not submit any personal data through our App. If you believe that we might have any information from or about a child under 16, please contact us at [email protected] or 1.888.700.7027.

1. 1. 21. Changes to This Privacy Notice

SCLogic may update this Privacy Notice from time to time to reflect company and customer feedback, and changes in our services or applicable laws. We encourage you to periodically review this Notice to stay informed of how we are protecting your information. Changes to this Privacy Notice are effective when they are posted on this page.

1. 1. 22. Updates and Amendments

You have the right to access and update or amend your personal data. If you need to correct or update your information, please contact us at [email protected].

1. 1. 23. Contact Information

SCLogic welcomes your comments regarding this Privacy Notice. If you have any questions or concerns about this Notice or our data processing practices, or if you wish to exercise your rights as a data subject, please contact us:

• Email: [email protected]
• Phone: 1.888.700.7027
• Postal Address:

SCLogic
Attn: Data Protection Officer
275 West St. Suite #400
Annapolis, MD, 21401
United States

1. 1. 24. Complaints

If you wish to make a complaint about how your personal data is being processed by SCLogic, please contact us at [email protected]. We will use commercially reasonable efforts to promptly investigate and resolve the complaint.

If you do not receive a response within 30 days, and you are an EU or UK resident, you have the right to lodge a complaint with your local data protection authority.

1. 1. 25. California Consumer Privacy Act (CCPA)
          • Information We Collect

This section applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months (collected information in bold):

1. 1. • Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

1. 1. • To fulfill or meet the reason you provided the information.
      • To provide you with information, products, or services that you request from us.
      • To provide you with alerts, event registrations, and other notices concerning our products or services.
      • To improve our App and present its contents to you.
      • For testing, research, analysis, and product development.
      • As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
      • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

1. 1. • Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information:

1. 1. • Access to Specific Information and Data Portability Rights: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
      • Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
      • Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise your rights under the CCPA, please submit a verifiable consumer request to us by contacting us at [email protected] or calling us at 1.888.700.7027.

1. 1. • Authorized Agent

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.

1. 1. • Verification Process

We may need to request additional information from you to verify your identity or understand the nature of your request.

1. 1. • Response Timing and Format

We endeavor to respond to verifiable consumer requests within forty-five (45) days of receipt.

1. 1. 26. Commitment to ISO Standards

SCLogic is committed to maintaining the highest standards of information security and privacy management. We have implemented an Information Security Management System (ISMS) in line with ISO/IEC 27001 and a Privacy Information Management System (PIMS) in line with ISO/IEC 27701 standards.

1. 1. 27. CAN-SPAM Act

In accordance with the CAN-SPAM Act, if at any time you would like to unsubscribe from receiving future communications, you can email us at [email protected], and we will promptly remove you from all correspondence.