2.0 Transparency/Notice–What Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with Scribd and the requirements of applicable law. We endeavor to collect information only relevant for the purposes of Processing. Below are the legal bases and some of the ways we collect information and how we use it.
Scribd collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Individuals”).
2.2 Information Scribd Collects
The data we collect from or about current, prospective and former Employees, customers, visitors and guests (collectively “Individuals”) includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, Internet Protocol address, and credit card and other financial information related to payments for services or goods. We may also collect other information that is not Personal Information, such as demographic information you choose to provide (e.g., your business or company information, professional experiences, educational background, nationality, ethnic origin, gender, interests, preferences and favorites) and answers to a security question and password.
2.3 How Scribd Collects Personal Information
Some of the ways that Scribd may collect your Personal Information include:
- Scribd may collect Personal Information from you through various channels, including the Site, the App, in surveys, during business or marketing events, and when delivering programs and services to you.
- When you use the Site and the App, Scribd may provide you with opportunities to sign up to receive specific information or services and may ask for your contact information (e.g. name, e-mail address or personal email address), so that we can send you specific information about our products, services and specific health conditions, with your consent.
- As you navigate Scribd, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access Scribd, and the Internet address of the website from which you linked directly to Scribd. This type of information is used for the purposes of gathering data to provide improved administration of Scribd, and to improve the quality of your experience when interacting with Scribd.
2.4 Information from Third-Party Sources
We may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you information about our business, products and services.
We may also offer you the ability to use Third Party services to enable additional features on Scribd. If you choose to do this, Scribd may receive information about you from these Third Parties.
2.5 Research/Survey Solicitations
From time to time, Scribd may perform research (online and offline) via surveys. We may engage Third Party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of the Site and the App, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
2.6 How Scribd Uses Your Personal Information
Depending on how you interact with Scribd, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:
- Providing Information and Services You Requested. Scribd may use the Personal Information about you to provide you information that you may request, e.g. information about a product or program we are offering. Scribd may also use your Personal Information to deliver a specific program or service to you, when you enroll to receive the program or service. Such use may include: (a) generally managing your information and accounts; (b) responding to questions, comments and requests; (c) providing access to certain areas and features; and (d) permitting you to register for events or participate in webinars.
- Marketing Products and Services. Scribd may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or services on Scribd. Scribd may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
- Research and Development. Scribd may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products, processes and services.
- Information Submitted Via Scribd. You agree that Scribd is free to use the content of any communications or other information submitted by you via Scribd, including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services. However, Scribd does not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a site will be published or otherwise used with your name on it; or (c) we are required to do so by law.
- Sharing Content with Friends or Colleagues. Scribd may offer various tools and functionality. For example, Scribd may provide functionality that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Scribd or any other Third Parties for any other purpose.
- Pseudonymous Data. Including as discussed below in Section 2.12, Scribd may use and share your anonymized or aggregated information within the Scribd group of companies or with Third Parties for, research, analytics and any other legally permissible purposes.
- Other Uses. Scribd may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
2.7 Human Resources Data
Scribd collects Personal Information from current, prospective and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave.
We acquire, hold, use and Process Human Resources-related Personal Information for a variety of business purposes including:
- workflow management, assigning, managing and administering projects;
- Human Resources administration and communication;
- payroll and the provision of benefits;
- compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- job grading activities;
- performance and employee development management;
- organizational development and succession planning;
- benefits and personnel administration;
- absence management;
- helpdesk and IT support services;
- regulatory compliance;
- internal and/or external or governmental compliance investigations;
- internal or external audits;
- litigation evaluation, prosecution and defense;
- diversity and inclusion initiatives;
- restructuring and relocation;
- emergency contacts and services;
- Employee safety;
- compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- acquisitions, divestitures and integrations.
2.8 Social Media
Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.
Scribd may collect Personal Information to enable Data Subjects to use online social media resources offered either by Scribd or a Third Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
2.9 Direct Mail, Email and Outbound Telemarketing
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings or phone calls from us with information on Scribd or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below.
2.10 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
2.10.2 Pixel Tags/Web Beacons
A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
2.10.3 Social Media Widgets
2.10.4 Analytics Information
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
2.11 Mobile Devices
Scribd may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. Scribd will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.
2.12 Anonymous and Aggregated Information
Scribd may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Scribd Website or other online services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site and App. Anonymized or aggregated information is not Personal Information, and Scribd may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within Scribd and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
3.0 Choice/Modalities to Opt Out
Where you have consented to Scribd’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section 3. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.
Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, Scribd will endeavor to obtain each Data Subject’s explicit consent (opt-in). Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, Scribd will comply with the law or contract.
3.2 Email and Telephone Communications
3.3 Human Resources Data
With regard to Personal Information that Scribd receives in connection with the employment relationship, Scribd will use such Personal Information only for employment-related purposes as more fully described in section 2.3 above. If Scribd intends to use this Personal Information for any other purpose, the Company will provide the Data Subject with an opportunity to opt-out of such uses.
3.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Scribd does not recognize or respond to browser-initiated DNT signals. For information about “do-not-track”, visit http://www.allaboutdnt.org.
3.5 Advertising Choices
You can opt out of the collection and use of your information for interest-based advertising by going to http://optout.aboutads.info, http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ to limit collection through the Website or by configuring the settings on your mobile device to limit ad tracking through the mobile applications.
Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on Scribd and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
4.0 Onward Transfer
4.1 Information We Share
4.1.1 Service Providers
Scribd may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
Scribd has executed appropriate contracts with the service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
4.1.2 Information Shared via Third Party Features
Scribd will share your information for as long as you use the Third Party feature. You can disable this at any time in your Scribd settings under Settings.
4.1.3 Business Partners
Scribd may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested Scribd may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Scribd’s. Scribd requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which it was provided.
4.1.4 Information Disclosed for Our Protection and the Protection of Others
We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Scribd policies or contracts; (v) to collect amounts owed to Scribd; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
4.1.5 Information Disclosed in Connection with Business Transactions
4.2 Data Transfers
All Personal Information sent or collected via or by Scribd may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Scribd, you consent to the storage of your Personal Information in these locations.
5.0 Rights of Access, Rectification, Erasure and Restriction
The security of all Personal Information provided to Scribd is important to us, and Scribd takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Scribd strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to Scribd, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at firstname.lastname@example.org
8.0 Redress/Compliance and Accountability
Scribd will address your concerns and attempt to resolve any privacy issues in a timely manner.
9.0 Other Rights and Important Information.
9.1 Information Regarding Children
Due to the nature of Scribd’s business, services and benefits are not marketed to persons less than 13 years of age (and in certain jurisdictions under the age of 16 (collectively “minors”).
If you are under 13 years of age (and in certain jurisdictions under the age of 16), then you may not use or access Scribd at any time or in any manner.
Protecting the privacy of young children is especially important. For that reason, Scribd does not knowingly collect or maintain personally identifiable information from minors. If Scribd learns that personally-identifiable information of minors has been collected on or through Scribd then Scribd will take the appropriate steps to delete this information.
If you are the parent or legal guardian of a minor who has become Scribd member, then please contact Scribd at email@example.com to have that minor’s account terminated and information deleted.
The following are some resources that may help parents and legal guardians in monitoring and limiting your childrens' access to certain types of material on the internet. While Scribd does not endorse these products, we are providing information about them as a public service to our community.
9.2 California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Scribd does not share Personal Information with third parties for their own marketing purposes.
9.3 Links to Third-Party Websites
9.5 Contact Information
Please contact Scribd with any questions or comments about this privacy notice, your personal information, and our third-party disclosure practices or your consent choices at: Scribd, Inc., 460 Bryant Street, Suite 100, San Francisco, CA 94107-2594, or by email: firstname.lastname@example.org. We will respond to your inquiry within 30 days of its receipt.
Scribd Privacy Notice (Effective: May 25, 2018)