Welcome to Strong Asian Lead (“Strong Asian Lead”, “SAL,” “we,” or “us”) and our web site at strongasianlead.com (the “Site”), as well as all related web sites, networks, applications, and other services provided by us and on which a link to this Privacy Policy (this “Policy”) is displayed (collectively, together with the Site, our “Service”).

This Policy explains how we collect, use, disclose, and protect information on the Service. By using the Service, you consent to the privacy practices described in this Policy.

This Policy is incorporated into and is subject to the Strong Asian Lead Usage Terms and Strong Asian Lead Core Principles as well as ScaleGrowth User Terms of Use and the ScaleGrowth Terms of Service.

1. THE INFORMATION WE COLLECT ON THE SERVICE

We collect information about you when you use the Service. The information we collect falls into two categories: (1) information you provide us; and (2) information we collect automatically.

a. Information You Provide Us. We collect information you provide us, including:

• Personal Information: We collect personal information that can identify you, such as your name, email address, mailing address, mobile phone number, and credit card or other billing information. We also collect other information you provide to us that could be linked to personal information, such as date of birth, geographic area, location, photo, or preferences. You provide us with this information when you register for an account, use the Service, make a purchase, or contact us for customer service-related requests.

b. Information We Collect Automatically. We also collect information automatically when you use the Service, including:

• Cookies and Similar Technologies: We use cookies, web beacons, and similar technologies to collect information about your activity, browser, and device. Cookies are small text files that are stored on your device when you access the Service. We use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your device until they expire or you delete them. We may use these technologies to personalize your experience, remember your preferences, and track your use of the Service.
• Log Data: When you use the Service, we automatically collect log data, such as your IP address, browser type, operating system, the pages or features of our Service you use, and the time and date of your visit. We use this information to operate, improve, and personalize the Service, and to analyze usage patterns.
• Analytics: We use third-party analytics tools, such as Google Analytics, to collect information about how you use and interact with the Service. These tools use cookies and similar technologies to collect and analyze information, such as how often you visit the Service, what pages you visit when you do so, and what other sites or apps you used prior to visiting the Service. We use this information to improve the Service and your experience.

2. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect for a variety of purposes, including:

• To provide, operate, and maintain the Service;
• To communicate with you, respond to your inquiries, and provide customer service;
• To personalize and improve the Service and your experience;
• To analyze usage trends and preferences and to develop new products, services, features, and functionality;
• To prevent fraud, protect our legal rights, and enforce our policies;
• To comply with legal obligations and regulatory requirements; and
• For any other purpose with your consent.

3. HOW WE SHARE INFORMATION

We may share the information we collect in various ways, including:

• Information from other sources. We may obtain information, including Personal Information, from third parties and sources other than the Service, such as our partners and advertisers. If we combine or associate information from other sources with Personal Information that we collect through the Service, we will treat the combined information as Personal Information in accordance with this Policy.

  4. How we use the information we collect. We use information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:

  • We use the information that we collect on the Service to operate, maintain, enhance and provide all features of the Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Service.

  • We use the information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, features, and functionality.

  • We may use your email address or other information we collect on the Service (i) to contact you for administrative purposes such as customer service or (ii) to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. Generally, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices”.

  • We may use cookies and automatically collected information we collect to: (i) personalize our Service, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.

  5. When we disclose information. Except as described in this Policy, we will not disclose your information that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

  • Any information that you voluntarily choose to include in a publicly accessible area of the Service will be available to anyone who has access to that content, including other users.

  • We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we either require them to agree to limit the disclosure of such information or rely on their privacy policies that require that they do so.

  • We may make certain automatically-collected, aggregated, or otherwise non-Personal Information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

  • We may disclose your information (i) if required to do so by law; (ii) in the good-faith belief that such action is necessary to comply with state and federal laws; (iii) in response to a court order, judicial or other government subpoena or warrant; or (iv) to otherwise cooperate with law enforcement or other governmental agencies.

  • We also reserve the right to disclose your information that we believeWith third-party service providers who help us provide and improve the Service, such as payment

    , in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

    CALIFORNIA PRIVACY RIGHTS

    If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

    • The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year
    • The names and addresses of the third parties that received the information
    • If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

    We may provide this information in a standardized format that is not specific to you. The designated email address for these requests is hello@strongasianlead.com.

    INTERNATIONAL DATA TRANSFERS

    We may transfer your Personal Information to countries other than the one in which you reside, including to the United States, where our servers are located. By using the Service, you consent to the transfer of your Personal Information to any country and/or territory where we or our service providers have facilities or engage third-party service providers, and to the processing of your information in accordance with this Policy.

    SECURITY

    We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Therefore, while we strive to protect your Personal Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Service cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party, despite our best efforts.

  PRIVACY OF MINORS

  This section emphasizes the importance of protecting the privacy of minors and clarifies that the website is not directed towards individuals under the age of 13. The website does not knowingly collect any personal information from individuals under 13 years of age, and if it discovers that it has collected such information without parental consent, it will take appropriate steps to delete it. Parents or guardians who discover that their child under 13 years of age has an account on the website can request that the child’s personal information be deleted.

  The next section is:

  DATA SECURITY

  This section outlines the physical, technical, and managerial safeguards that the website employs to protect the integrity and security of personal information that it collects and maintains. While the website makes efforts to safeguard personal information, it cannot warrant the security of any information transmitted to it or stored on the website. If the website becomes aware of a security systems breach, it will attempt to notify affected users electronically.

  The next section is:

  PRIVACY SETTINGS

  This section clarifies that although the website may allow users to adjust their privacy settings to limit access to certain personal information, no security measures are perfect or impenetrable. The website is not responsible for circumvention of any privacy settings or security measures on the website. It cannot control the actions of other users with whom users may choose to share their information. Even after information is removed from the website, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the website. The website cannot guarantee that information posted on or transmitted to the website will not be viewed by unauthorized persons.

  The next section is:

  INTERNATIONAL VISITORS

  This section clarifies that the website is hosted in the United States and is intended for visitors located within the United States. If users choose to use the website from regions outside of the United States with different data collection and use laws, they are transferring their personal information to the United States for storage and processing. The website may transfer user data from the United States to other countries or regions in connection with data storage and processing, fulfilling user requests, and operating the website. By providing any information, including personal information, on or to the website, users consent to such transfer, storage, and processing.

  The final section is:

  CHANGES AND UPDATES TO THIS POLICY

  This section clarifies that the website may update this Policy from time to time and advises users to periodically check the page to stay informed of any changes. If the modifications materially alter user rights or obligations under this Policy, the website will make reasonable efforts to notify users of the change, such as sending an email or generating a pop-up or banner notification. Users’ continued use of the website after the revised Policy has become effective indicates that they have read, understood, and agreed to the current version of this Policy.

  PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at: Strong Asian Lead, info@strongasianlead.com.

  GDPR PRIVACY RIGHTS FOR EEA RESIDENTS This section applies to you if you reside in the European Economic Area (an “EEA Resident”). A data controller means a party that is responsible for deciding how it uses the data that it holds. A user using the Service to create a community is the data controller of your data that the user collects through the community and is responsible for handling the requests you may make with respect to that data. We are the data controller of your data that we collect as described in this Policy, and we will handle any requests that you may make with respect to that data as described below.

  You have the right to ask us not to process your Personal Information for marketing purposes. We will usually inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your Personal Information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information. You can also exercise the right by contacting us directly.

  If you are an EEA Resident and GDPR applies and we hold your Personal Information in our capacity as a data controller, you may object to our processing of Personal Information or request that we:

  • Provide access to and/or a copy of certain Personal Information (including, in some cases, in portable form);
  • Prevent the processing of your Personal Information for direct-marketing purposes (including any direct marketing processing based on profiling);
  • Update Personal Information that is out of date or incorrect;
  • Delete certain Personal Information which we are holding about you, provided that the Personal Information is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim;
  • Restrict the way that we process and disclose certain of your information except to the extent that processing is required (i) to comply with a legal obligation under European Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims;
  • Transfer your Personal Information to a third party to the extent that this is technically feasible; or
  • Honor a revocation of your consent for the processing of your Personal Information (without retroactive effect).

  We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include information that we need to keep processing for our legitimate interests or to comply with a legal obligation. We may request that you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern as we would be happy to try to resolve it directly.

  If you are an EEA Resident in France, you also have the right to set guidelines for the retention and communication of your Personal Information after your death.

  If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us privacy@asianfilmnetwork.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

  In addition, where you believe that we have not complied with our obligation under this Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office. Here is a list of local data protection authorities in EEA countries.

  CHANGES TO THIS POLICY

  We reserve the right to change this Policy from time to time, with or without notice to you, in our sole and absolute discretion. The most current version of this Policy will be posted on the Service, and your continued use of the Service after we make changes constitutes your acceptance of such changes.

  CONTACT US

  If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights and choices under this Policy, please contact us at:

  Strong Asian Lead
  hello@strongasianlead.com
  Attention: Legal Department