Privacy Policy

Effective as of July 31, 2024.
Last updated July 31, 2024.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us in the event you have a complaint.

This privacy policy (the “Privacy Policy”) applies to the RelaxScofa mobile application available as mobile iOS, Android, as well as the online-accessible software and progressive web application (the “App” or “RelaxScofa”). The purpose of this Privacy Policy is to explain how Scofa, LLC and its subsidiaries and affiliates (together, “Scofa”, “we” or “us”) collect, use, and disclose your information when you use or access our website, mobile application, and other online products and services (collectively, the “Services”), or when you interact with us through social media, customer service, or otherwise. We may change this Privacy Policy from time to time. If we make changes, we will revise the date at the top of the policy and, in some cases, we may provide you with additional notice. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws. The GDPR defines a “controller” as one who is responsible for the personal data collected by a company or organization.

This policy also explains the rights of California residents regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We may update and make changes to this policy, so we encourage you to review it periodically.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

“Scofa,” we, us, our

Scofa, LLC

6405 W Gulf to Lake Hwy

Crystal River, FL 34429

Email: support@scofa.com

Sensitive personal
information or
Personal
Information

Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular user, or household; Any information relating to an identified or identifiable individual; Personal information revealing a user’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a user’s health, sex life, or sexual orientation, contents of a user’s mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information.

2. Personal Information We Collect About You. Personal information is required to provide the RelaxScofa Software and associated Services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing said Software and associated Services to you.

In the preceding twelve (12) months, we have collected and may collect and use the following categories and specific types of user personal information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers).	Names, Email Addresses, Login Information.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, bank account number, credit card number, debit card number, or any other financial information.	Name, Addresses, Telephone Number, Payment Information.
Internet or other electronic network activity information (e.g., browsing history, search history, access dates and times, and information regarding a user’s interaction with an Internet Web site, application, or advertisement).	Browsing history, Internet Protocol Addresses, Device Information, User Interaction.
Transactional information related to the purchase and sale of goods.	Name, Account Billed and Associated Addresses, Product Descriptions, Price Descriptions.

3. How Your Personal Information is Collected.We collect most of this personal information directly from you via our Mobile Application, as well as our on-line website and progressive web application located at RelaxScofa.com. However, we may also collect information:

Directly from a third party (e.g., internet service providers, developers, data analytics providers, government entities); and
Automated information collection via our IT systems, including:
- Automated monitoring of our PWA and other technical systems, such as our computer networks and connections, and communications systems; and
- Communications within the Software.

4. Use of Cookies. Your browser may use “cookies” to personalize your online experience. A cookie is a text file that is placed on your hard disk by a web server. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. The primary purpose of cookies is to provide enhanced features and to save you time. A cookie tells the web server that you have returned to a specific web page. For example, if you register with our website, a cookie helps us to recall your information on subsequent visits. This simplifies the processing of your personal information, such as remembering your shipping address, etc. As a result, when you return to our website, the information you previously provided can be retrieved for your convenience.
There are many different types of cookies, however, our Website, Mobile Application, and PWA uses the following types of cookies:

Functionality – We use these cookies so that we recognize you on our software and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website.

5. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason. We collect user personal information for the following business purposes:

Helping to ensure security and integrity to the extent the use of the user’s personal information is reasonably necessary and proportionate for these purposes;
Supporting and maintaining the Services, including debugging to identify and repair errors that impair existing intended functionality (in accordance with the user agreement between you and Scofa);
Developing new products and services to enhance our services;
Providing transaction messages to you, including receipts, account notifications, customer service responses, and other administrative messages;
Contacting with you about Scofa and other companies’ products, services, and events, ask for feedback, and send you news and other updates. To opt out of marketing messages, see the “Your Choices” section below;
Analyzing trends, usage, and activities related to the Services;
Protecting Scofa and others’ rights and property through detection, investigation, and prevention, including enforcing our policies and agreements;
Ensure compliance with the law, including by processing transactional records for tax filings;
Making anonymized or aggregated data that cannot reasonably be used to identify you;
For our legitimate interests or those of a third party; or
Where you have given consent.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide RelaxScofa Software and associated services	For the performance of our contract or to take steps at your request before entering a contract
To prevent and detect fraud against you or your company	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity; Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business; Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies; Statutory returns	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use; Statistical analysis to help us manage our business	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information; Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information and prevent and detect criminal activity; To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract or to take steps at your request before entering into a contract; To comply with our legal and statutory obligations
Marketing our services to: existing and former customers, third parties who have previously expressed an interest in our services, and third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party, i.e., to promote our business
Developing new products and services to enhance our services	For our legitimate interests in improving and developing new software
Providing transaction messages to you, including receipts, account notifications, customer service responses, and other administrative messages	For our legitimate interest in improving and developing new services
Contacting with you about Relax Scofa, Scofa, and other companies’ products, services, and events, ask for feedback, and send you news and other updates	For our legitimate interest in improving and developing new services
Analyzing trends, usage, and activities related to the Service	For our legitimate interest in improving and developing new services
Protecting Scofa and others’ rights and property through detection, investigation, and prevention, including enforcing our policies and agreements	For our legitimate interest in preventing fraud, as well as protecting and securing our assets, customers, employees, and the public
Ensure compliance with the law, including by processing transactional records for tax filings	To comply with our legal obligations under applicable law, including taxation and consumer protection laws
Making anonymized or aggregated data that cannot reasonably be used to identify you	For our legitimate interest in creating non-personally identifiable data that will help us improve our services, provide reports to third parties, and enhance and promote our business in other ways

6. Categories of Personal Information We Disclosed for a Business Purpose. As described in this Privacy Policy or at the time of collection, we may disclose personal information for a business purpose to one or more third parties. The following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household may be disclosed to third parties for business purposes:

Identifiers;
Geolocation data;
Information that identifies, relates to, describes, or is capable of being associated with a particular individual, including but not limited to, his or her name, and Login information;
Commercial information (e.g., records of products or services purchased, obtained, or considered, to other purchasing or consuming histories or tendencies); and
Internet or other network activity information (e.g., information regarding a user’s interaction with the Internet Website, Mobile Application, or PWA.

7. Who We Share Your Personal Information With. Your personal information may be disclosed for a business purpose to the following third parties:

Our affiliates, including companies within the Scofa or RelaxScofa group;
Service providers we use to help deliver our Software and Services to you, e.g., providers of email services, payment processors, fraud prevention vendors, analytics providers, advertising partners, application stores and platforms, and others;
Professional business advisors under appropriate confidentiality obligations, e.g., accountants, auditors, lawyers, and others;
Other third parties we use to help us run our business, such as marketing agencies or website hosts; and
Law enforcement or public authorities, where required by law, e.g., court orders, subpoenas, or other lawful requests.

In addition, we may disclose to third parties aggregated or other information that is not subject to the data protection laws of your jurisdiction.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8. Where Your Personal Information is Held. Information may be held at our offices and those of our affiliates, providers, and agents as described above or remotely through these persons (“Who We Share Your Personal Information With”). Personal Information obtained by RelaxScofa is stored with Google Secured Servers.

9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing RelaxScofa and the associated Services to you. Thereafter, we will keep your personal information for as long as necessary:

To respond to any questions, complaints, or claims made by you or on your behalf;
To show that we treated you fairly; and
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize or de-identify it.

10. Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

With your and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. If you would like further information, please contact us (see “How To Contact Us” below).

11. Your Rights Under the GDPR.

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

12. Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

- The categories of personal information we have collected about you, including sensitive personal information;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting selling, or sharing personal information;
- The categories of third parties with whom we disclose or share personal information, if any; and
- The specific pieces of personal information we have collected about you.

Please note that we are not required to:

- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
- Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Disclosed or Used for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

- The categories of personal information about you that we disclosed and the categories of third parties to whom the personal information was disclosed; and
- The categories of personal information we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed.

Right to Opt Out

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt out of the disclosure of your personal information, we will refrain from sharing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information. To opt-out: relaxscofa.com/support.

Right to Limit Use of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the goods reasonably expected by an average user who requests those goods or services; To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the user’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a user’s current interaction with the business, provided that the user’s personal information is not disclosed to another third party and is not used to build a profile about the user’s or otherwise alter the user’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers or contractors to delete your personal information from their records. Direct third parties to whom the business has shared your personal information to delete your personal information unless impossible or involves disproportionate effort. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a warranty, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Help to ensure security and integrity to the extent the use of the consumer’s user’s personal information is reasonably necessary and proportionate for those purposes; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another user to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation or Discrimination	You have the right to not be retaliated against and/or discriminated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: Deny services to you; Charge different prices or rates for services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of services to you; or Suggest that you will receive a different price or rate for services or a different level or quality of services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

13. Use of HTTPS for Data Transmission. To ensure the security and privacy of your data, we utilize Hypertext Transfer Protocol Secure (HTTPS) for all transmissions between your device and our servers. HTTPS encrypts data exchanged between your browser and our website using Transport Layer Security (TLS), providing a secure channel over which your information travels. This encryption prevents unauthorized access and eavesdropping while transferring sensitive data, such as personal information, login credentials, and payment details. Key aspects of RelaxScofa’s HTTPS implementation include:

Encryption: Data is encrypted using advanced cryptographic algorithms, safeguarding against interception and tampering during transmission.
Authentication: Our HTTPS certificates verify the identity of our website, ensuring that you are connecting to our legitimate servers and not an impostor site.
Integrity: HTTPS guarantees that the information you transmit and receive remains unchanged in transit, maintaining its integrity and reliability.

14. Use of Google Cloud for Data Storage. For robust and reliable data storage, we utilize Google Cloud Storage, a service provided by Google LLC. This allows us to store and manage your data in a secure, scalable, and highly available environment. Google Cloud Storage is designed to meet stringent security and compliance requirements, ensuring your data is always protected. Key features of Google Cloud Storage include:

Security: Google Cloud employs multiple layers of security, including data encryption at rest and in transit, to protect your data from unauthorized access.
Compliance: Google Cloud complies with numerous international standards and regulations, such as GDPR, ISO/IEC 27001, and SOC, ensuring that our storage practices meet the utmost standards of safeguarding data and privacy.
Availability: Google Cloud offers high availability and redundancy, storing your data across multiple locations, providing resilience against hardware failures, and ensuring uninterrupted access.
Scalability: Google Cloud Storage scales seamlessly to accommodate our growing data needs, allowing us to store large volumes of data efficiently and cost-effectively.

15. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

16. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please email or write to us at the contact information below. If you choose to contact us directly, please provide us with the following information:

Enough information to identify and contact you;
Proof of your identity and address; and
A description of what right you wish to exercise and the information to which the request relates.

Please note that you may only make a CCPA/CPRA related data access or data portability disclosure request twice within a 12-month period.

We are not obligated to make a data access or portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf.

Any personal information we collect to verify identity in connection with your request will be used solely for verification purposes.

Logging into your account will allow you to update certain account information such as your password, name, and email address. In accordance with applicable laws, you have the right to request to:

Learn more about the information we have about you;
Access, correct, and/or delete information we have about you; and
Opt out of “sales,” targeted advertising, or “sharing.”

For decisions that have legal or similarly significant effects, you have the right to limit sensitive personal data processing or to opt out of profiling. In the event that you request the deletion of your information, please note that we are under a legal obligation to retain certain information. You can exercise these rights by contacting us at relaxscofa.com/support. You may be asked to provide information that matches what we already have on file in order to verify your request.

By contacting relaxscofa.com/support, you may appeal our decision if we deny your request. You may contact the attorney general in your state if you are concerned about the outcome of the appeal.

17. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

18. Promotions and Notifications. RelaxScofa offers the option to opt out of receiving promotional emails. Our non-promotional emails, such as those about your account or our ongoing business relationships, may still be sent to you if you opt out.

Push notifications are sent to your mobile device with your consent. Changing your mobile device’s notification settings will allow you to turn off these messages at any time.

Contact Us. If you have any questions about this Privacy Policy, please contact us at relaxscofa.com/support.

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