Website Privacy Policy

1. INTRODUCTION

1. Important information and who we are

Welcome to Scriba Technologies Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

Scriba Technologies Ltd is a company registered in England and Wales with registered company number 15899866 and trading as “Scriba”. We are registered with the Information Commissioner’s Office under number ZB819920.

At Scriba Technologies Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy  and Personal Data in compliance with the United Kingdom General Data Protection  Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and  regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy  Policy will tell you about your privacy rights and how the law protects you..

The data subjects from whom we may gather and process Personal Data may include (but is not limited to):

• Prospects
• Customers
• Suppliers
• Business contacts
• Third parties connected to your customers (for example, API integration partners)

This Privacy Policy applies to all Personal Data directly processed by us in the capacity of Data Controller. It does not apply to Personal Data uploaded by our customers during the normal use of our systems or services (in which capacity we act as a Data Processor).. Please see our separate Data Processing Agreement for information on how we process data uploaded to the Scriba platform.

2. Your Data Controller

Scriba Technologies Ltd is your Data Controller and responsible for your Personal Data.

We are not required by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to  privacy@scriba.digital or by post to Unit 1a Brewery Court, North Street, Bristol BS3 1JS.

You have the right to make a complaint at any time to the Information Commissioner’s  Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We  would, however, appreciate the chance to deal with your concerns before you approach  the ICO so please contact us in the first instance.

3. Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees and sub-contractors who may deal with your data on our behalf (known as “Processors”). The responsibilities below may be  assigned to an individual or may be taken to apply to the organisation as a whole. The  Data Controller and our Processors have the following responsibilities:

1. Ensure that all processing of Personal Data is governed by one of the legal bases  laid out in the GDPR (see 2.2 below for more information);
2. Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of  confidentiality;
3. Implement appropriate technical and organisational measures to ensure a level of  security appropriate to the risk associated with the processing of Personal Data;
4. Obtain the prior specific or general authorisation of the Controller before engaging  another Processor;
5. Assist the Controller in the fulfilment of the Controller's obligation to respond to  requests for exercising the data subject's rights;
6. Make available to the Controller all information necessary to demonstrate  compliance with the obligations laid down in the GDPR and allow for and contribute  to audits, including inspections, conducted by the Controller or another auditor  mandated by the Controller;
7. Maintain a record of all categories of processing activities carried out on behalf of a  Controller;
8. Cooperate, on request, with the supervisory authority in the performance of its  tasks;
9. Ensure that any person acting under the authority of the Processor who has access  to Personal Data does not process Personal Data except on instructions from the  Controller; and
10. Notify the Controller without undue delay after becoming aware of a Personal Data  Breach;
11. Designate a data protection officer where required by the GDPR, publish their details  and communicate them to the supervisory authority; and
12. Support the data protection officer in performing their tasks by providing resources  necessary to carry out those tasks and access to Personal Data and processing  operations and to maintain their expert knowledge.
13. In making use of Google API services with customers, the principles of the Google API Service Data Policy will be complied with.

2. LEGAL BASIS FOR DATA COLLECTION

4. Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can  be identified. It does not include data where the identity has been removed (anonymous  data).

"Aggregated Data" means data compiled from multiple sources or individual data points that have been combined or summarised in such a way that individual identities are no longer directly revealed.

We may collect, use, store and transfer different kinds of Personal Data about you which  we have grouped together below. Not all of the following types of data will necessarily be  collected from you but this is the full scope of data that we collect and when we collect it  from you:

14. Profile/Identity Data: This is data relating to your first name, last name, gender, date of  birth.
15. Contact Data: This is data relating to your phone number, addresses, email addresses,  phone numbers.
16. Marketing and Communications Data: This is your preferences in receiving marketing  information and other information from us.
17. Financial Data: These are your banking details e.g. your account number and sort code.
18. Transactional Data: This is information of details and records of all payments you have made for our services or products.
19. Workplace: Where you work.
20. Job Role: The role you undertake at your workplace.

We also collect use and share Aggregated Data such as how often users complete their onboarding processes. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand  and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not  identify you personally. We may share this type of anonymous data with others, including  service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details  about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,  political opinions, trade union membership, information about your health, and genetic  and biometric data). Nor do we collect any information about criminal convictions and  offences.

5. The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and  processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when  you tick a box that confirms you are happy to receive email newsletters from us, or  ‘opt in’ to a service.

“Contractual Obligations”: We may require certain information from you in order  to fulfil our contractual obligations and provide you with the promised service.

“Legal Compliance”: We’re required by law to collect and process certain types of  data, such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be  able to meet our legitimate interests - this covers aspects that can be reasonably  expected as part of running our business, that will not have a material impact on  your rights, freedom or interests. Examples could be your address, so that we know  where to deliver something to, or your name, so that we have a record of who to  contact moving forwards.

3. HOW WE USE YOUR PERSONAL DATA

6. Our data uses

We will only use your Personal Data when the law allows us to. Set out below are the different types of Personal Data we collect and the lawful basis for processing  that data. Please refer to section 2.2 for more information on the lawful bases listed in the table below. Examples provided in the list below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and a related purpose. For further inquiries please contact us at privacy@scriba.co.uk.

7. Marketing and content updates

You may receive marketing and new content communications from us unless you  specifically request that you would not like to receive these communications. You can opt out of these communications at any time. From time to  time we may make suggestions and recommendations to you about goods or services that may be of interest to you. Again, you may specifically opt out of these communications by contacting us at privacy@scriba.co.uk.

8. Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we  reasonably consider that we need to use it for another reason and that reason is  compatible with the original purpose. Please note that we may process your Personal Data without your knowledge or consent,  in compliance with the above rules, where this is required or permitted by law.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

9. Your control over Scriba Technologies Ltd’s use of your Personal Data

           Your account information will be protected by a password for your privacy and security.  

You need to prevent unauthorised access to your account and personal information by  selecting and protecting your password appropriately and limiting access to your  computer or device and by signing off after you have finished accessing your account.

You will need to contact us if you would like to delete your account.

10. How Scriba Technologies Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. We implement a variety of security measures to ensure the security of your  Personal Data on our systems, including a strong password enforcement, two factor authentication systems, staff training and data residency control.

Any Personal Data  collected by us is only accessible by a limited number of employees who have special  access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our  possession. However, unfortunately no transmission of data over the internet is  guaranteed to be completely secure. It may be possible for third parties not under the control of Scriba Technologies Ltd to intercept or access transmissions or private communications  unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us immediately.

11. Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by contacting us at  any time by emailing us at privacy@scriba.digital.

Where you opt out of receiving these marketing messages, we will continue to retain other  Personal Data provided to us as a result of interactions with us not related to your  marketing preferences.

12. How to request your data and the process for obtaining it 

You will not have to pay a fee to access your Personal Data (or to exercise any of the other  rights). However, if your request is clearly unfounded, we could refuse to comply with your  request.

We may need to request specific information from you to help us confirm your identity  and ensure you have the right to access your Personal Data (or to exercise any of your  other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further  information in relation to your request to speed up our response.  

5. YOUR DATA AND THIRD PARTIES

13. Sharing your data with third parties

We may share Personal Data with interested parties in the event that Scriba Technologies Ltd anticipates a change in control or the acquisition of all or part of our business or assets or  with interested parties in connection with the licensing of our technology.

If Scriba Technologies Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of  your Personal Data. In all other situations your data will still remain protected in  accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy.

We may also share your Personal Data with subcontractors or affiliates or service providers providing IT services and data storage services.

6. HOW LONG WE RETAIN YOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. AGE LIMIT FOR OUR USERS

You must not use Scriba unless you are aged 18 or older. If you are under 18 and you access Scriba by lying about your age, you must immediately stop using Scriba.

This website is not intended for children and we do not knowingly collect data relating to children.

8. INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the UK or other countries or jurisdictions  outside the UK. By using Scriba, you are permitting and consenting to  the transfer of information, including Personal Data, outside of the UK.

9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here. This version is dated as at the date given in the footer.

By contacting, forming a relationship with, or using the products of Scriba Technologies Ltd, you consent to the collection and use of data by us as set out in this Privacy  Policy. Continued access or use of Scriba Technologies Ltd will constitute your express acceptance of any  modifications to this Privacy Policy.

10. INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated  examples are not intended to in any way limit the term which they serve to illustrate. Any email  addresses set out in this policy may be used solely for the purpose for which they are stated to  be provided, and any unrelated correspondence will be ignored. Unless otherwise required by  law, we reserve the right to not respond to emails, even if they relate to a legitimate subject  matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your  request or question is polite, reasonable and there is no relatively obvious other way to deal with  or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of Scriba Technologies Ltd, waive rights or make representations  (whether contractual or otherwise). If anything contained in an email from a Scriba Technologies Ltd address  contradicts anything in this policy, our terms or any official public announcement on our website,  or is inconsistent with or amounts to a waiver of any Scriba Technologies Ltd’s rights, the email content will be read  down to grant precedence to the latter. The only exception to this is genuine correspondence  expressed to be from the Scriba Technologies Ltd’s legal advisers.