PRIVACY STATEMENT

This Privacy Statement (“Statement”) describes how the Company (“Company,” “we,” or “us”) treats personal information about you when you access or use our websites, applications, and other online sites (collectively “Sites”). Your use of our Sites is predicated on your agreement with this Statement, and so, if you do not agree with this Statement, then please do not use our Sites. This Statement does not apply to information collected or used for employment-related purposes. The Company has separate, internal privacy practices and notices with regard to personal information that is collected from prospective, current, and former employees and job applicants.

Types of Information We Collect
How We Collect Your Information
How We Use Your Information
Targeted Advertising and Analytics
How We Disclose Your Information
Children Under 13
Rights and Choices Regarding Your Information
Your California Privacy Rights
Security
Transfer of Information
Data Retention
Links
How to Contact Us
Changes in Statement

TYPES OF INFORMATION WE COLLECT

We collect information from you and about you. The information we collect about you depends on how you interact with us or use our Sites. Here are some examples of the information we may collect:

Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
Information You Submit. We may collect information you choose to provide, including your Contact Information, when you send us a message through the “Contact Us” page or similar features on our Sites, submit through an online comment, contact our sales, or support teams, or otherwise communicate with us.
Business Information. For example, we may collect your business contact information. We may also collect information about your employer and your job title.
Demographic Information. We may collect demographic information such as your date of birth, age, education, and zip code.
Sensitive Information. We may collect certain sensitive personal information, including identification numbers and information revealing racial or ethnic origin.
Device Information. For example, we may collect information about how you access our Sites, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version.
Account Information. Certain portions of the Sites may allow you to create a user account. In connection with that account, we may collect your username and password.
Commercial Information. We may collect personal information that could identify you and relates to the products or services in which you are interested or have considered or purchased. We may also collect personal information about your purchasing habits, or consuming history or tendencies.
Usage Information. We may collect information regarding your activity on our Sites. For example, we may collect information regarding what Site features are useful or most frequently used, access times, pages viewed, and links clicked.
Information We Derive. We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are interested in certain services provided by the Company based on your browsing behavior.
Other Information. If you use our Sites, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us. If you use our app, we might look at how often you use the app and where you downloaded it.

HOW WE COLLECT INFORMATION

We collect your information in different ways. Below are some examples of how we may collect your information.

Directly From You. We collect information you provide directly to us. For example, when you:
- Register for an account.
- Submit an inquiry to us.
- Register for an event.
- Complete an online form.
- Contact support team.
- Interact with our social media pages.
- Otherwise interact with us.

Passively. For example, when you:
- Visit and navigate our Sites on any device.
- Enable location-based features on our Sites.
- Click on a sponsored link or third-party advertisement.

We may also collect information about users over time and across different websites, apps, and devices when you use the Sites.

From Third-Parties. We may receive information about you from other sources. For example, this may include receiving information from:
- Our business partners, including online advertising networks and analytics vendors.
- Social media sites, including Facebook, Twitter, YouTube, Pinterest, Snapchat
- Your contacts or friends who provide your information to us because they think you may be interested in our services.
- Companies that provide information to supplement what we already know about you, including data aggregators. Certain third-parties might link your name or email address to other information they have collected. That might include online usage information.

Through the Use of Cookies and Similar Tracking Technologie. We use tracking technologies, such as cookies and pixels, to collect information about your interactions with the Sites. These technologies help us improve our Sites and your experience, see which areas and features of our Sites are popular, and count visits. For more information about the cookies and other tracking technologies we use, and the choices available to you, see the Rights and Choices Regarding Your Information section below.

By Combining Information. For example, we may:
- Combine information that we collect offline with information we collect through our Sites.
- Combine information we collect about you from the different devices you use to access our Sites.
- Combine information we get from third parties with information we already have about you.

HOW WE USE YOUR INFORMATION

We may also collect information about users over time and across different websites, apps, and devices when you use the Sites.

To Run and Improve Our Sites and Business. We may use your information to make our Sites and business better. We may also use your information to provide you with information about our business.
To Provide Client Support. This includes responding to client support requests.
To Respond to Your Requests or Questions. This may include responding to your feedback.
To Communicate with You. We may communicate with you about your account or our relationship. We may also contact you about this Statement or our Site terms and conditions.
For Marketing Purposes. We may provide you with information about our company and our business initiatives. This includes using your information to personalize your experience on our Sites. For more information about your choices related to these communications, see the Rights and Choices Regarding Your Information section below.
For Targeted Advertising Purposes. We may target advertising to you when you use our Sites based on information provided by our advertising partners (for more information and to opt out see the Targeted Advertising and Analytics section below).
For Administrative Purposes. This includes using your information for accounting, record keeping, backup, and administrative purposes.
For Security Purposes. This could include protecting our company and clients who use our services. It may also include protecting our Sites.
For Scholarship Application Purposes. We may use certain sensitive personal information, including identification numbers and information revealing racial or ethnic origin, to evaluate your scholarship application and candidacy.
As Otherwise Permitted or Required by Law or As We May Notify You.

TARGETED ADVERTISING AND ANALYTICS

We engage others to provide analytics services, serve advertisements, and perform related services across the web and in applications. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Sites, including your IP address, web browser and network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information is used to deliver advertising targeted to your interests on other companies’ sites or apps and to analyze and track data, determine the popularity of certain content, and better understand your activity. In addition, some of our advertising partners also enable us to translate your email address or phone number into an identifier that can’t be used to identify you personally. Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web and in apps. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain laws.

HOW WE DISCLOSE YOUR INFORMATION

In certain circumstances, we disclose (or permit others to directly collect) information about you. We may disclose the categories of personal information described above in the following ways:

With Our Affiliates. We may disclose your information with our parent, subsidiary, and other affiliated entities.
With Our Service Providers. We may disclose your information with third parties who perform services on our behalf. For example, this may include companies that assist us with web hosting, fraud prevention, customer service, marketing, and advertising.
With Our Business Partners. For example, this may include data aggregators, advertisers, media buying agencies, advertising networks and advertising service providers.
For Corporate Transactions. For example, if we merge with, acquire or are acquired, or sell part of our business to another entity, we may disclose personal information in connection with, or during negotiations of, such corporate transactions. This may include an asset sale, corporate reorganization or other change of control.
To Comply with the Law or To Protect Ourselves and Others. For example, this could include responding to a court order or subpoena. It could also include disclosing information if a government agency or investigatory body requests. We might disclose information when we are investigating a potential fraud.
With Professional Advisors. We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
Where You Have Asked Us or Provided Consent to Disclose Your Information with a Third-Party. We make personal information available to third parties if you directed us to do so or when we have your consent.
For Other Reasons We May Describe to You.

We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you. The Company processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

CHILDREN UNDER 13

We do not knowingly collect personally identifiable data from persons under the age of 13 and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act), and any other applicable privacy laws. If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at privacy@sceco.co. You can also write to us at the address listed at the end of this Statement.

RIGHTS AND CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your information. Certain choices you make are browser and device specific.

OPTING OUT OF TARGETED ADVERTISING, SHARING AND SALES

As described in the Targeted Advertising and Analytics section above, we process personal information to understand and improve your experience with our Sites and to serve you advertisements. Some of these activities may be considered “sales” or “sharing” of your personal information or “targeted advertising” under certain privacy laws. Depending on where you reside, you may have the right to opt out of targeted advertising, sharing, and sales of your personal information. You can do so by following the prompts.

MARKETING COMMUNICATIONS:

You can opt out of receiving our marketing communications by using the unsubscribe link within each email. Note that, as long as you maintain an account with us or receive services, you will continue to receive administrative messages from us regarding your account and the services.

NON-DISCRIMINATION:

We will not discriminate against you for exercising your privacy rights.

COOKIES & OTHER TRACKING TECHNOLOGIES

Cookies:We use cookies and similar tracking technologies to analyze visits to and use of our Sites and interactions with our marketing communications. Most web browsers are set to accept cookies by default. You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depend on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.
Flash Cookies:You may need to take an additional action to manage flash cookies, which you can learn more about here. Why? Because flash cookies cannot be controlled through your browser settings.
Google Analytics:We may use Google Analytics on our Sites to help us understand how you use our Sites. You can learn about how to opt-out of Google Analytics here.
Email Tools:You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.
Note that deleting or blocking cookies may impact your experience on our Sites, as some features may not be available. Certain options you select are browser and device specific.

MOBILE PUSH NOTIFICATIONS:

With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

OUR DO NOT TRACK POLICY:

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
Options you select are browser and device specific.

OTHER RIGHTS INCLUDING ACCESS, CORRECTION AND DELETION

You may also have the right to assert a legal right regarding our collection and use of your information under applicable law, depending on where you reside. Under these applicable laws, you may have a number of rights, including:
- The right not to provide your personal information to us;
- The right to object, stop, or limit the processing of your personal information;
- The right to request the erasure or restriction of processing of your personal information in our possession;
- The right to have your information transferred to another data controller in a portable format;
- The right to withdraw your consent;
- The right to access to your information and request from us a description, or a copy, of the types of personal information we have stored about you; and
- The right to request an update, correction or amendment of your personal information.
To exercise any of these rights (as applicable), or to request more information, contact us at privacy@sceco.coor through the contact information listed at the bottom of this Statement.
We may verify your request by asking you to provide information related to your recent interactions with us. If we deny your request, you may appeal our decision by contacting us by emailing privacy@sceco.co or by calling +93 (0) 799 00 9494. If you have concerns about the results of an appeal, you may contact the attorney general in the state where you reside.

ADDITIONAL DISCLOSURE S:

We collect the following categories of personal information: identifiers, commercial information, internet or other electronic network activity information, geolocation data, education information, inferences, and sensitive personal information. For more information about the specific data points, we collect and the sources of such collection, please see the Types of Information We Collect and How We Use Your Information sections above.

We collect personal information for the business and commercial purposes described in the How We Use Your Information section above.

In the preceding 12 months, we have disclosed personal information for the business and commercial purposes described in the Disclosure of Information section above. Specifically, we have disclosed the following categories of personal information to the following categories of recipients:

*Category of Personal Information*	*Categories of Recipients*
· Identifiers (such as name and address) · Commercial Information (such as company and role) · Internet or other electronic network activity information · Education information · Audio, electronic, visual, thermal, olfactory, or similar information · Professional and employment information · Inferences	· Advertising networks · Internet service providers · Data analytics providers · Government entities · Operating system and platforms · Social networks · Data brokers

Category of Personal Information

Categories of Recipients

· Identifiers (such as name and address)

· Commercial Information (such as company and role)

· Internet or other electronic network activity information

· Education information

· Audio, electronic, visual, thermal, olfactory, or similar information

· Professional and employment information

· Inferences

· Advertising networks

· Internet service providers

· Data analytics providers

· Government entities

· Operating system and platforms

· Social networks

· Data brokers

We do not use or disclose sensitive personal information or any purpose other than what is specified.

Some of our advertising and analytics activities may constitute “sharing” or “selling” under Afghanistan law. In order to advertise our products to you and better understand, improve, and personalize our interactions with you, we share and sell the following categories of personal information to the following categories of third parties:

*Category of Personal Information*	*Category of Third Parties*
· Identifiers · Commercial Information · Internet or other electronic network activity information	· Advertising Networks · Data analytics providers and brokers

Category of Personal Information

Category of Third Parties

· Identifiers

· Commercial Information

· Internet or other electronic network activity information

· Advertising Networks

· Data analytics providers and brokers

We do not knowingly sell or share personal information about consumers under the age of 16.

LEGAL BASIS: FOR PROCESSING

When we process your personal data as described above, we do so in reliance on the following lawful bases:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

DATA SUBJECT REQUEST

Please see the Rights and Choices Regarding Your Information section above for more information about your privacy rights and how to exercise them. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please contact us at privacy@sceco.com.

SECURITY

We take appropriate steps to preserve the security of your personal information, including preventing them from being distorted, damaged or disclosed to unauthorized third-parties. We use reasonable means to safeguard personal information under our control.

However, the Internet is not 100% secure. We cannot promise that your use of our Sites will be completely safe. We encourage you to use caution when using the Internet. A username and a password are needed to access certain areas of our Sites. Consequently, it is your responsibility to protect your username and password.

DATA RETENTION

We store personal data for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Statement.

LINKS

Our Sites may contain links to other third-party sites that are not governed by this Statement. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third-party sites.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Statement, or wish to update your information, please feel free to contact us at privacy@sceco.com or by telephone at +93 (0) 799 00 9494. You may also write to us at the following address:

Privacy Officer
c/o Squad Construction & Engineering
1003, 3^rd Floor Haroon Market, Between Haji Yaqub
and Ansari Square, Shahr-e-Naw, Kabul, Afghanistan.

CHANGES IN STATEMENT

We reserve the right to revise this Statement from time to time and will post an updated copy of our Privacy Statement on our Sites. If we make changes, we will notify you by revising the date at the top of this Statement. It is your responsibility to review this Statement periodically to ensure that you understand any revisions to it. Again, if you do not agree with this Statement, please do not use our Sites.

Effective Date: 4/1/2023 Last Updated: 4/1/2023