Last Updated: March 21, 2025

The following Privacy Policy governs the online information collection practices of Full Scale LLC (“Full Scale,” “we,” “us,” “our”) as it relates to your use of the EngagePath products and services. This policy outlines the types of information we gather while you use our website (engagepath.com), the EngagePath Chrome Extension, and our SaaS platform, as well as how we use this information.

EngagePath is a collection of products, including a Chrome Extension and SaaS platform, designed to enable social selling. Users may be registered or non-registered users of the services (“Service(s)”) provided by Full Scale. We process your data in accordance with applicable laws and regulations, following industry best practices.

1. PURPOSE AND SCOPE

This Privacy Policy primarily applies to information that we collect online, but it may also apply to information collected offline (e.g., phone or mail communications).

Additionally, while providing our services on behalf of our registered users, we may collect information related to viewers. The use of information collected on behalf of our users is governed primarily by our contractual agreements with them and their privacy policies. We are not responsible for third-party privacy policies or their data collection practices.

For users of the EngagePath Chrome Extension, additional privacy considerations apply, including:

Permissions requested and their purposes

Handling of browsing data and local storage

Data security and retention practices

2. HOW WE COLLECT DATA ABOUT YOU

We may collect different types of data depending on how you use EngagePath.

A. Data Provided by Registered Users

Account Creation and Login

When you use the EngagePath Chrome Extension, create an account, or log into your account, we may collect the following personal information:

First name

Last name

Social media account (if linked)

Email address

Password

B. Data Collected Through Automated Means

1. System Data

We may collect technical data about your device to improve functionality and performance, such as:

Device type

Operating system

Browser type and version (for Chrome Extension users)

IP address

2. Browsing Data (Only for Chrome Extension Users)

If permitted by the user, the EngagePath Chrome Extension may access limited browsing data to enable features such as:

Interacting with specific social media platforms

Enhancing productivity and automation features

We do NOT collect your full browsing history, nor do we track your activity beyond what is necessary for the extension’s intended use.

3. User-Generated Content

We collect information and materials that users voluntarily provide, including:

Text, photos, and videos associated with their EngagePath account

Comments, messages, or other content generated within the service

C. Data Collected from Third Parties

Integration with Third-Party Services

When you connect EngagePath to your social media accounts or other third-party services, we may store data relevant to enabling the Service.

For Chrome Extension users:

The extension may request permissions to interact with social media accounts but does not store login credentials.

Some integration data may be stored locally on your device to improve functionality.

D. Data Collected During Transactions

For users engaging in paid services or transactions, we may collect:

Type of service requested

Order details

Payment & transaction information (merchant name, payment method, amount)

Date and time of the transaction

We use third-party payment processors for transactions and do not store credit card or banking details on our servers.

3. CHROME EXTENSION-SPECIFIC DATA COLLECTION

When you install and use the EngagePath Chrome Extension, we may collect additional information to facilitate its functionality.

A. Permissions and Justification

The EngagePath Chrome Extension may request the following permissions:

"tabs" permission – Allows the extension to access and modify specific tabs for functionality.

"storage" permission – Saves user preferences and local session data on the device.

"clipboardWrite" permission – Enables copying and pasting content as part of the extension's features.[1]

We do NOT collect or store full browsing history or personal data beyond what is necessary for the extension’s function.

B. Local Storage and Data Retention

Some information, such as user settings and preferences, may be stored locally in the browser.

This data is not transmitted to our servers unless explicitly required for authentication or syncing between the Chrome Extension and SaaS platform.

Removing the Chrome Extension deletes all locally stored data.

4. HOW WE USE YOUR PERSONAL INFORMATION

We use your data to:

Provide and improve our services

Manage your account and authentication

Respond to customer support inquiries

Enable Chrome Extension features

Prevent fraud and ensure security

We do NOT sell, rent, or trade personal data.

5. WHO HAS ACCESS TO YOUR DATA?

A. Within Our Organization

Access to user data is limited to employees who require it for service delivery, including:

Customer support

Product development

Marketing (if the user has opted in)

B. Third-Party Processors

We may use service providers for:

Payment processing

Analytics

Data hosting

Feature enablement

We ensure these providers adhere to strict data protection policies through contractual agreements.

Some of our processors may operate outside your country of residence, including in the United States. When data is transferred internationally, we ensure that appropriate safeguards are in place - such as Standard Contractual Clauses (SCCs) or equivalent frameworks - to comply with applicable data protection laws, including the GDPR.

C. Compliance with Legal Obligations

We may disclose personal information when required to do so by law or when such disclosure is necessary to:

Comply with a legal obligation, regulation, subpoena, or court order

Respond to lawful requests by public authorities

Protect the rights, property, or safety of Full Scale LLC, our users, or others

D. Transfer of Business

If we (or our assets) are acquired, or if we go out of business, enter bankruptcy or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.

6. DATA RETENTION AND DELETION POLICY

We retain your data only as long as necessary for the purposes outlined in this policy. For most users, server-stored data is retained for a standard period of 60 days following account termination unless otherwise required by law or regulatory compliance.

For Chrome Extension users:

Locally stored data is deleted when the extension is uninstalled.

Data synced with our servers (e.g., authentication tokens or usage activity) is subject to the same 60-day retention window after account deletion or inactivity.

To request deletion, email us at [email protected].

7. SECURITY MEASURES

We employ a combination of technical, administrative, and organizational safeguards to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption protocols to protect data during transmission (e.g., HTTPS/SSL) and, where applicable, at rest

Secure access controls, such as multi-factor authentication and role-based permissions, to ensure that only authorized personnel can access sensitive data

Regular security audits and vulnerability assessments to identify and mitigate risks

Employee training on data privacy, security best practices, and phishing awareness

While we follow industry best practices, no method of data transmission or storage is completely secure. Therefore, we encourage users to take their own precautions as well - such as using strong passwords, logging out from shared devices, and promptly reporting any suspicious activity.

8. YOUR RIGHTS UNDER GDPR & CCPA

If you are located in the European Union (EU) under the General Data Protection Regulation (GDPR), or in California under the California Consumer Privacy Act (CCPA), you are entitled to certain rights regarding your personal data. These rights may include:

The right to access the data we hold about you

The right to request deletion of your personal data

The right to correct or update inaccurate or incomplete personal data

The right to opt out of data processing for marketing or analytics (where applicable)

The right to know what categories of personal information we collect and how it is used

The right to withdraw consent at any time if our processing is based on your consent

The right to request a copy of your data in a structured, commonly used, and machine-readable format (data portability)

Under the GDPR, we process your personal data based on one or more of the following legal bases:

Your consent, which you may withdraw at any time

Our contractual obligation to deliver EngagePath services

Our legitimate interest in operating, maintaining, and improving the platform

To exercise any of these rights, or if you have questions about how we process your data, please contact us at [email protected]. We will respond to your request within a reasonable timeframe, typically within 30 days.

9. OUR POLICY ON CHILDREN’S DATA

EngagePath is not directed to children under the age of 13, and we do not knowingly collect personal information from anyone under 13 in accordance with the Children’s Online Privacy Protection Act (COPPA). Additionally, our services are intended only for individuals aged 18 and older. If we learn that we have inadvertently collected personal data from a child, we will take steps to delete it promptly.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal obligations, or for other operational reasons.

When we make material changes - such as updates to the types of data we collect, how we use it, or who we share it with - we will take appropriate steps to notify you. This may include:

Posting an updated version of the policy on our website

Updating the “Last Updated” date at the top of the policy

Sending you an email or in-app notification (if you are a registered user)

For changes that affect users in jurisdictions with enhanced data protection laws (such as the GDPR or CCPA), we will comply with applicable notification or consent requirements.

We encourage you to review this Privacy Policy periodically. Continued use of EngagePath after changes become effective constitutes your acceptance of the updated policy.

11. CONTACT US

If you have privacy-related questions or concerns, please reach out to us at [email protected], or for general inquiries, use [email protected].