SABX Privacy Notice

Last Updated: May 19, 2020

SABX Digital Xchange (“SABX,” “we,” “us,” and “our”) is a sophisticated, easy-to-use platform that enables sellers and their buyers to interact and transact with ease and efficiency in a completely digital environment. This Privacy Notice explains how we collect, use, disclose, and otherwise process Personal Information in connection with our services. When we use the term “Services,” we are referring to all the services we offer on your behalf, including, without limitation, our product and service offerings and the websites, mobile applications, and services that link to this Privacy Notice. Please read this information carefully. This Privacy Notice is not a contract and does not create any legal rights or obligations.

This Privacy Notice does not cover or address services that we provide solely on behalf of a third party or Personal Information and privacy practices relating to our job applicants, employees and other personnel.

Region-Specific Disclosures. We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

  • If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@sabx.com.

What is Personal Information?

When we use the term “Personal Information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

Our Collection of Personal Information

We collect Personal Information about individuals when they visit our site, register for an account, send us feedback, request early access or a demo, or interact on our platform. Sometimes we collect Personal Information automatically when an individual interacts with our Services and sometimes we collect the Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources and third parties, even before our first direct interaction.

Personal Information You Provide. We may collect the following Personal Information you provide in connection with our Services, including:

  • Contact Information, including first name, last name, email address, mailing address (including zip code), phone and facsimile numbers, job title, company name and location;
  • Payment Information, including payment status, billing address, billing phone number and purchase history information. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our site.
  • Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our site.
  • Buyer Content Information, including information about how you use the Services, your actions on the Services, content you upload or post to the Services, interactions and communications between users on the Services, any content you provide through in-app messages, chat or other functionality, photos and videos you post to the Services, and any other buyer content information.
  • User Account Information, including user account information for tenant and internal admin accounts.

Personal Information Automatically Collected. We may collect certain personal information automatically when you visit our Services, including:

  • Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
  • Analytics Data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”).
  • Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.

Personal Information from Third Parties. We may also obtain Personal Information from third parties; which we often combine with Personal Information we collect either automatically or directly from you.

We receive the same categories of Personal Information as described above from the following sources and third parties:

  • Social Media. When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Facebook, Twitter, LinkedIn, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
  • Service Providers. Our service providers that perform services solely on our behalf, such as analytics providers, collect Personal Information and often share some or all of this information with us. For example, we receive Personal Information from our service providers that conduct marketing or analytics activities.
  • Business Partners. Our business partners, such as our technology partners or channel partners, may collect Personal Information in connection with the services provided and may share some or all of the information with us. For example, we receive Personal Information from our partners such as customer contact information.
  • Security Providers. We may share your Personal Information with third-party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule, regulation or the policies of SABX.
  • Publicly Available Sources. We collect Personal Information about individuals that we do not otherwise have, including contact information, employment-related information and product-interest information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our services, to pre-populate online forms, and to better understand the demographics of our users.
  • Other Third Parties. From time to time, we may receive information about individuals from third parties. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing information about an individual.

Our Use of Personal Information

We may use Personal Information we collect to:

  • Manage our organization and its day-to-day operations;
  • Communicate with individuals and our customers, including via email, text message, social media and/or telephone calls;
  • Market our Services to individuals and potential customers, including through email, direct mail, phone or text message;
  • Administer, improve and personalize our site and Services, including by recognizing an individual and remembering their information when they return to our site;
  • Identify and analyze how individuals use our site and Services;
  • Conduct research and analytics on our customer base and our Services;
  • Improve and customize our service offerings to address the needs and interests of our customer base and other individuals we interact with;
  • Text, enhance, updates and monitor the Services, or diagnose or fix technology problems;
  • Help maintain the safety, security and integrity of our property and Services, technology assets and business;
  • Defend, protect or enforce our rights or applicable contract and agreements;
  • Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
  • Comply with legal obligations.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.

Our Disclosure of Personal Information

We may disclose Personal Information in the following ways:

  • Within SABX. We are able to offer you the products and services we make available because of the hard work of our team members across all SABX entities. SABX entities disclose Personal Information to other SABX entities for purposes and uses that are consistent with this Privacy Notice.
  • Affiliates. We may share Personal Information with other companies owned or controlled by SABX, and other companies owned by or under common ownership as SABX, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services
  • Our Service Providers. We engage third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, administrative services, marketing and advertising services, and other similar services.
  • Business Partners. We may disclose Personal Information to third parties with whom we partner to provide joint promotional activities or co-branded services, such as webinars, and such disclosure is necessary to fulfill the services, requests or applications. Typically, these partners will be identified in the relevant promotional information.
  • Ad Networks and Advertising Partners. We may work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other sites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
  • Security Providers. We may share your Personal Information with third-party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule, regulation or the policies of SABX.
  • Business Transaction or Reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • Legal Obligations and Rights. We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws or to respond to lawful requests and legal process;
    • to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
    • to detect, suppress, or prevent fraud;
    • to reduce credit risk and collect debts owed to us;
    • to protect the health and safety of us and others; or
    • as otherwise required by applicable law.
  • Otherwise With Consent or Direction. We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our site or service-related publications.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

California Privacy Rights

California’s “Shine the Light” law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to privacy@sabx.com or write us at our postal address in the Contact Us section below.

Control Over Your Information

You may control your information in the following ways:

  • Device Information. You may control the mobile app’s access to your device information through the app settings on your device. For instance, you can withdraw permission for the app to access your address book, location, photo stream and camera.
  • Communication Preferences. You can stop receiving push notifications by changing the app “Notification settings.” From time to time, we may contact you with information about our products and services, including sending you email marketing messages and asking for your feedback on our products and services. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of administrative- and technical services-related communications (e.g., account verification, transactional communications, changes/updates to features of our Services, and technical and security notices).
  • Account Information. If you have an online account with us, then you have the ability to modify certain information in their account (e.g., contact information) and may change some of your data sharing preferences through the app settings on your device. Please note, however, some information, such as past transactions, logs of technical support calls, or other information may not be modified or deleted. After you change or alter any information, SABX may require reverification of your information and as a result, you may experience delays in your ability to use the Services after any such change until SABX is able to perform its verification. For questions about modifying or updating any information in an account, please contact us using the information provided in the Contact Us section below. Please note that SABX does not own or control the Personal Information uploaded to the Services by our users, and cannot modify or delete Personal Information except at the request of our users, or as permitted by our Terms of Service. Please contact the user you have a direct relationship with to request a modification or deletion of account information.

Cookies

We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect other information and to enhance your experience using the Services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online services, as some features and services on our online services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Third-Party Analytics & Advertising

We may use one or more third-party analytics services (such as Google Analytics) to evaluate your use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services. We may also permit third-party online advertising networks, social media companies and other third-party advertising services to collect information about your use of our Website over time so that they may play or display ads on our Website, on other devices you may use, and on other websites, apps or services, including on Facebook. These third parties may use cookies, pixel tags (also called web beacons or clear gifs) and other technologies to help analyze and provide us with data and to collect data about consumers directly through our Services for purposes of analyzing and optimizing our Services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud.

We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). The Principles allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements.  Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again. If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online Services.  It means that the online ads that you do see from DAA program participants should not be based on your interests.  In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Some of the third-party analytics and advertising partners we engage may also provide their own disclosures and opt-out mechanisms in relation to their collection of information from other websites, like our Website. For example, you can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy here and you can view Google’s currently available Google Analytics opt-out options here.

We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Children’s Personal Information

Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information.

Links to Third-Party Websites or Services

Our websites and online services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy notices.

Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Last Updated” date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@sabx.com.

Alternatively, inquiries may be addressed to:

SABX, Inc.

1389 Center Drive

Suite 200

Park City, Utah 84098