SCALECART PRIVACY POLICY

Operated by Adfluence LLC

Effective Date: 5/13/26   |   Last Updated: 5/13/26

This Privacy Policy explains how Adfluence LLC ("Adfluence," "we," "us," or "our") collects, uses, discloses, and protects information in connection with the ScaleCart software-as-a-service platform and our websites (collectively, the "Service"). By using the Service, you acknowledge the practices described below. This Policy is incorporated into and forms part of the ScaleCart Terms and Conditions.

1. Scope and Our Two Roles

Adfluence plays two distinct roles with respect to personal information processed in connection with the Service:

1.1 Controller / Business

We act as a "controller" (GDPR/UK GDPR), "business" (CCPA/CPRA), or equivalent with respect to personal information we collect directly from our customers and prospects — for example, account holders ("Subscribers"), people who fill out a form on our marketing website, or visitors to scalecart.com.

1.2 Processor / Service Provider

We act as a "processor" (GDPR/UK GDPR), "service provider" (CCPA/CPRA), or equivalent with respect to personal information that our Subscribers collect through their own funnels, landing pages, checkout forms, opt-in forms, and integrations built on the Service ("End-User Data"). In this role, the Subscriber is the controller and decides what data is collected, how it is used, and where it is routed. Our role is limited to processing End-User Data on the Subscriber's instructions to make the Service function and to route data to the Subscriber's connected integrations (such as their payment processor, email service provider, CRM, or analytics tool).

If you are an End User (a visitor, lead, or customer of one of our Subscribers), the Subscriber — not Adfluence — is the party responsible for the collection and handling of your information. You should review the privacy policy of the Subscriber whose funnel you interacted with. Requests to access, correct, delete, or otherwise exercise rights with respect to End-User Data should be directed to that Subscriber. We will refer such requests to the relevant Subscriber and assist them as reasonably required

2. Information We Collect

2.1 Information You Provide to Us (Subscribers)

- Account information: name, business name, email address, password (hashed), phone number, country, time zone, and similar profile data.

- Billing information: billing name and address, billing email, last four digits of payment card, card brand and expiration, and tax identifiers. Full payment card numbers are collected and stored by our payment processor (e.g., Stripe), not by Adfluence.

- Communications: messages you send to our support, sales, or success teams, including any attachments, transcripts of chats, and feedback you submit.

- Content you upload: copy, images, video, files, lists, templates, and other materials you upload to your Account.

2.2 Information Collected Automatically

- Usage and log data: pages visited, features used, clicks, timestamps, referring URLs, IP address, browser type, operating system, device identifiers, and error and crash reports.

- Funnel analytics: aggregated and per-page statistics about visits to funnels you build, including visitor IP addresses, geolocation derived from IP, pages viewed, conversion events, and form submission rates — used to power the analytics dashboards in your Account.

- Cookies, pixels, and similar technologies: see Section 6 for details on cookies set by Adfluence and by our marketing-and-advertising partners on our own marketing website.

2.3 End-User Data (Processed on Behalf of Subscribers)

When a Subscriber's funnel is visited, opted into, or used to complete a transaction, the Service may handle data the Subscriber chooses to collect from their End Users, such as names, email addresses, phone numbers, shipping and billing addresses, order details, and any other fields the Subscriber adds to their forms.

Our handling of End-User Data is limited to what is necessary to operate the Service and route data to the destinations the Subscriber has configured (for example, their payment processor, email service provider, CRM, or fulfillment system). End-User Data is processed for the limited and specified purpose of providing the Service on the Subscriber's instructions and is not used by Adfluence to build marketing profiles, sell to third parties, train models without authorization, or for any independent business purpose. End-User Data may be stored only as long as reasonably necessary to deliver the Service (including transient storage during routing, transaction records, fraud-prevention logs, and any retention required for legal, audit, or security purposes).

2.4 Information from Third Parties

We may receive information about you from third parties, including authentication providers (if you sign in with a third-party account), payment processors (transaction status and risk signals), analytics and advertising partners, fraud-prevention services, and publicly available sources. We combine this information with the data described above for the purposes set out in Section 3.

3. How We Use Information

We use the information described in Section 2 for the following purposes (and, where required by GDPR/UK GDPR, on the lawful bases noted):

- Provide, operate, and maintain the Service and your Account, including authenticating you, hosting your Funnels, and processing transactions you initiate (performance of a contract).

- Process payments, manage subscriptions, and prevent fraud and abuse (performance of a contract; legitimate interests).

- Provide customer support, respond to inquiries, and communicate with you about your Account (performance of a contract; legitimate interests).

- Improve, test, and develop the Service, including measuring feature usage, debugging, and analytics (legitimate interests).

- Send transactional emails (e.g., receipts, security notices, service updates) (performance of a contract).

- Send marketing communications about Adfluence products and features, subject to your right to opt out at any time (legitimate interests; consent where required).

Personalize your experience and recommend templates, features, or content (legitimate interests).

- Detect, prevent, and investigate security incidents, fraud, and violations of our Terms (legitimate interests; legal obligation).

- Comply with legal obligations, respond to lawful requests from authorities, and enforce our agreements (legal obligation; legitimate interests).

- With your consent, for any other purpose disclosed to you at the time we collect the information.

We do not sell personal information for monetary consideration, and we do not use End-User Data for cross-context behavioral advertising. See Section 8 for additional state-law-specific disclosures.

4. How We Share Information

We share personal information only as described below.

4.1 Service Providers and Subprocessors

We share information with vendors that perform services on our behalf and are contractually bound to handle it only on our instructions and in accordance with applicable law. These include hosting and infrastructure providers (e.g., AWS, Google Cloud, or Cloudflare), payment processors (e.g., Stripe), email and SMS delivery providers, analytics providers, customer-support tools, error-monitoring tools, and fraud-prevention vendors. A current list of our subprocessors is available upon request and, for GDPR purposes, in our Data Processing Addendum.

4.2 Integrations Configured by Subscribers

Where a Subscriber configures an integration (for example, connecting their Funnel to Stripe, a CRM, an email tool, or a fulfillment platform), data flows through the Service to the configured destination on the Subscriber's instructions. Adfluence is not responsible for how those third-party services handle data once received; their use is governed by their own terms and privacy policies.

4.3 Affiliates and Corporate Transactions

We may share information with our affiliates for the purposes described in this Policy and, in the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business, may transfer information as part of that transaction, subject to standard confidentiality protections.

4.4 Legal and Safety

We may disclose information when we believe in good faith that it is necessary to (a) comply with applicable law, legal process, or a binding request from a public authority; (b) enforce our Terms; (c) detect, prevent, or address fraud, security, or technical issues; or (d) protect the rights, property, or safety of Adfluence, our Subscribers, End Users, or the public.

4.5 With Your Direction or Consent

We may share information with other parties when you direct us to or otherwise consent.

5. International Data Transfers

Adfluence is based in the United States, and our service providers operate in multiple countries. If you access the Service from outside the United States, your personal information will be transferred to, stored in, and processed in the United States and other jurisdictions, which may have data-protection laws different from those in your country.

Where required by law (including for transfers from the EEA, UK, or Switzerland), we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, the Swiss Addendum, and supplementary measures as appropriate. A copy of the applicable safeguards is available upon request.

6. Cookies and Similar Technologies

We use cookies, web beacons, local storage, and similar technologies on our marketing website and in the Service for the following purposes:

- Strictly necessary: authentication, session management, security, and load balancing.

- Functional: remembering preferences such as language, theme, and recently used features.

- Analytics: understanding how visitors use our marketing website and the Service (e.g., Google Analytics or similar).

- Marketing and advertising (marketing site only): measuring the effectiveness of our advertising campaigns and showing relevant ads on third-party platforms (e.g., Meta Pixel, Google Ads, LinkedIn Insight Tag).

- Subscribers are independently responsible for the cookies, pixels, and tracking technologies they deploy on their own Funnels, including obtaining any required user consent and providing required disclosures.

You can manage cookies through your browser settings and, where required by law, through our cookie consent banner. Some features of the Service may not function correctly if you disable certain cookies.

7. Data Retention and Security

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Account data is generally retained for the duration of your Account plus a reasonable period thereafter for backup, audit, tax, and legal-defense purposes. End-User Data is retained per the Subscriber's instructions and is deleted or returned upon termination of the Subscriber's Account, subject to legal-retention requirements.

We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction, including encryption in transit, access controls, logging, and vendor due diligence. No method of transmission or storage is 100% secure, however, and we cannot guarantee absolute security.

8. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights with respect to personal information we collect about you as a "business":

- Right to know: request the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties with whom we share it.

- Right to delete: request that we delete personal information we have collected about you, subject to legal exceptions.

- Right to correct: request correction of inaccurate personal information.

- Right to opt out of sale or sharing: although we do not "sell" personal information for monetary consideration, certain uses of cookies on our marketing website for cross-context behavioral advertising may be considered "sharing" under the CPRA. You may opt out using the "Do Not Sell or Share My Personal Information" link on our website or by enabling the Global Privacy Control (GPC) signal.

- Right to limit use of sensitive personal information: we do not use sensitive personal information for purposes beyond those permitted by the CPRA without your consent.

- Right to non-discrimination: we will not discriminate against you for exercising any of these rights.

You may submit a request by emailing [email protected] or using the privacy request form linked from our website. We will verify your identity before fulfilling a request. Authorized agents may submit requests with proof of authorization. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

9. Your Rights Under the GDPR and UK GDPR

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights with respect to personal information we hold about you as a controller:

- Right of access to your personal information.

- Right to rectification of inaccurate or incomplete personal information.

- Right to erasure ("right to be forgotten") in certain circumstances.

- Right to restriction of processing in certain circumstances.

- Right to data portability in certain circumstances.

- Right to object to processing based on legitimate interests, including direct marketing.

- Right to withdraw consent at any time where processing is based on consent (withdrawal does not affect the lawfulness of prior processing).

- Right to lodge a complaint with your local supervisory authority. For UK residents, the Information

Commissioner's Office (ICO) is the lead authority.

To exercise any of these rights, contact us at [PRIVACY EMAIL]. We do not appoint an EU/UK representative under Article 27 of the GDPR unless required and, where required, our representative's contact details are listed at the end of this Policy.

Where you are an End User of a Subscriber's funnel, the Subscriber is the controller and you should direct requests to them. We will refer your request to the appropriate Subscriber and assist as reasonably necessary.

10. Your Rights Under Canadian Law (PIPEDA and Provincial Laws)

If you are located in Canada, you have rights under the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial laws (e.g., Quebec's Law 25), including the right to access, correct, and withdraw consent to our processing of your personal information, and the right to file a complaint with the Office of the Privacy Commissioner of Canada or applicable provincial commissioner. To exercise these rights, contact us at [email protected].

THE ADFLUENCE PARTIES DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, ERROR-FREE, OR FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, THAT ANY DATA WILL BE PRESERVED OR ACCURATE, OR THAT YOUR USE OF THE SERVICE WILL PRODUCE ANY PARTICULAR RESULT, INCLUDING ANY LEVEL OF SALES, CONVERSIONS, INCOME, OR BUSINESS OUTCOMES. ANY EXAMPLES, TEMPLATES, OR CASE STUDIES PROVIDED ARE FOR ILLUSTRATIVE PURPOSES ONLY AND ARE NOT A GUARANTEE OF RESULTS.

11. Children’s Privacy

The Service is intended for users aged 18 and over and is not directed to children under 13 (or under 16 in the EEA/UK). We do not knowingly collect personal information directly from children. If you believe we have collected information from a child without appropriate consent, please contact us and we will take appropriate steps to delete it. Subscribers are independently responsible for compliance with COPPA, age-gating, and similar requirements with respect to End Users of their funnels.

12. Do Not Track

Our Service does not respond to "Do Not Track" signals at this time because no uniform industry standard for compliance has been adopted. We do honor the Global Privacy Control (GPC) signal where required by California law.

13. Automated Decision-Making and Profiling

We do not engage in automated decision-making that produces legal or similarly significant effects on individuals without human involvement. We may use automated tools for spam filtering, fraud detection, and analytics; these tools do not produce legally significant outcomes on their own.

14. Marketing Choices

You can opt out of marketing emails by clicking the "unsubscribe" link in any marketing email we send, or by emailing [email protected]. Even if you opt out of marketing, we may continue to send transactional and Service-related communications.

15. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. Material changes will be communicated by reasonable means (e.g., in-Service notification or email). Your continued use of the Service after the effective date of any update constitutes acceptance of the revised Policy.

16. How to Contact Us

If you have questions about this Privacy Policy or our practices, please contact us at:

Adfluence LLC

2363 stag run blvd

Clearwater, Florida 33765

Email: [email protected]

For data-subject and consumer privacy requests, please use the subject line "Privacy Request" and include sufficient information for us to verify your identity.

© 2026 Adfluence LLC. All rights reserved.

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