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PRIVACY POLICY

 

Effective Date: 15 August 2022

Last Updated on: 09 August 2023

This privacy policy (“Policy”) explains how Scribble Data Private Limited or any of its affiliates or subsidiaries (“Scribble Data”, “We”, “Us”, “Our”) Processes Personal Data collected from You.

  1. DEFINITIONS

    Terms not specifically defined herein shall have the meaning ascribed thereto in the License Agreement.

1.1. “Controller” means  any person who alone or in conjunction with others, determines the purposes and means of the processing of Personal Data.

1.2. “End-User” means any person with whom the Customer interacts using Scribble Enrich.

1.3. “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.4. “Processing/To Process” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

1.5. “SPDI” means sensitive personal data or information of a natural person as defined in Rule 3 of the SPDI Rules.

1.6. “SPDI Rules” means the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.

1.7. “License Agreement” shall mean the License Agreement entered into between Scribble Data and the Customer governing the use of Scribble Enrich, and includes any other agreement relating to the use of the Scribble Enrich platform or related products or services. 

1.8. “Website(s)” means the websites that We own and operate.

1.9. “You” and “Your” means an identified or identifiable natural person from whom we collect Personal Data as a Controller, as specified in Section 2 of this Policy.

1.10. “Customer” means any person that enters into the License Agreement referred to in Section 1.7. 

1.11. “Customer Data” means any personal data provided by the Customer to Scribble Data through the Scribble Enrich platform or any other related products or services covered by the License Agreement. 

1.12. “Scribble Enrich” means the platform made available by Scribble Data to the Customer for its own use or its End-Users, including any related products or services that may be covered by the License Agreement.

  1. PERSONAL DATA COLLECTED BY US

2.1. You directly provide Us with most of the data We collect. We collect Personal Data from You directly as follows: a) When You purchase a license of Scribble Enrich, We collect account information including Your name, e-mail address, billing address, phone number of the account administrator or information required for authentication of a Customer’s license of Scribble Enrich; b) When You submit forms on Our Website(s) or as You use interactive features of the Website(s), including providing feedback or suggestions, testimonials, making requests, participation in surveys, or promotions, We collect Your feedback, name and e-mail address; c) When You attend an event conducted by Us or our community partners, including webinars or seminars, We and/or Our community partners may collect Your contact information such as name, e-mail address, phone number, designation and company name; d) When You interact with Us on public forums, Our social media channels, Our community forums, or Our blogs, We collect the information You provide Us while interacting with Us and Personal Data such as Your name, location and any information You provide in Your bio while registering with such forums; e) When You apply for a job with Us, whether through Our Website or otherwise, We collect Your Personal Data, including Your resume, in connection with Your job application; f) When You are a representative of Our business partners, suppliers or vendors, We collect Your name, e-mail and contact information; (g) When You visit Our office or participate in forums organized by Us, We collect Your name, email address, phone number, company name and time and date of arrival.

2.2. We may also receive Your Personal Data indirectly as follows: a) from third party sources like marketing lists, databases, and social media but only where We have checked that these third parties either have Your consent or are otherwise legally permitted or required to disclose Your Personal Data to Us; b) When You use Scribble Enrich, We automatically collect information on the type of device You use, the operating system version and IP address, to perform Our agreement with You; c) When You use or view Our Website(s), information is collected via Your browser’s cookies as described in clause 10 herein; d) We may also collect or receive Your Personal Data from other sources such as Our business or channel partners through whom You create or access Your Account, publicly available sources, email add-ons and/ or through the combining of information We obtain from third parties along with the Personal Data You provide to Us. (e) You can log in to Scribble Enrich sign-on services which will authenticate Your identity and share certain personal information with us such as Your name and email address.

2.3. The Website(s) includes social media features and widgets that are either hosted by a third-party or hosted directly on the Website(s) and Your interaction with these social media features and widgets is governed by the privacy statement of the companies that provide them. You should check Your privacy settings on these third-party services to understand and change the information sent to Us through these services.

  1. LEGAL BASIS FOR PROCESSING

3.1. If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it. We will normally collect Personal Data from You only where We need it to perform a contract with You, where the Processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We Process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

3.2. If You are a resident of India, We collect Your Personal Data where We have Your consent as required under the SPDI Rules for the purposes mentioned in Clause 4. We shall, prior to collecting Your Personal Data, provide You the option to not provide Personal Data to Us. Where You opt to not provide Personal Data to Us, We shall have the option to not provide Scribble Enrich under the License Agreement for which the Personal Data is required.

3.3. If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause 13.

  1. PURPOSES FOR WHICH PERSONAL DATA WILL BE PROCESSED

    We Process Your Personal Data to: a) facilitate Your access to the Website(s); b) process and complete payment transactions; c) send You communication on Your use of Scribble Enrich, new features in Scribble Enrich or new service offerings; d) perform Our obligations or receive products/services in accordance with any contract that We may have with You, Your organization or Your service provider; e) Organize events or for other marketing/ promotional activities; f) investigate and prevent fraudulent transactions, unauthorized access to the Website(s) and Scribble Enrich, and other illegal activities; g) personalize the Website(s) and Scribble Enrich; h) evaluate You for the job position that You have applied for or any position that We consider You suitable for, to ensure that We can make the best recruitment decisions, and i) for other purposes for which We obtain Your consent; j) to improve our services, to conduct research and other similar purposes.

  1. SHARING OF PERSONAL DATA

5.1. You acknowledge that We will share Your Personal Data with Our group companies and third-party service providers so that they may offer You Scribble Enrich and/or to send information or updates on the Scribble Enrich if You are a Customer. For information on the specific third parties with whom we share Your Personal Data, please write to privacy@scribbledata.io.

5.2. When We Process Your order where You are a Customer, We may send Your Personal Data to and also use the resulting information from credit reference agencies to prevent fraudulent purchases.

5.3. We share Personal Data with Our third-party service providers that host and maintain the Our Website(s), applications, backup, storage, payment processing, analytics and other services. These third-party service providers may have access to or Process Your Personal Data for the purpose of providing these services to Us.

5.4. We may share Your Personal Data with third-party providers who assist Us in marketing and promotions in compliance with applicable laws.

5.5. We may be required to disclose Your Personal Data in response to: a) lawful requests by public authorities, including to meet national security or law enforcement requirements; b) subpoenas, court orders, or legal process, and/or c) to establish or exercise Our legal rights or defend against legal claims.

5.6. We may share Your Personal Data to assist investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the License Agreement, or as otherwise required by law.

5.7. We may also share Your Personal Data with an entity to which we divest all or a portion of our business, or otherwise in connection with a merger, consolidation, change in control, reorganization or liquidation of all or a portion of Our business.

  1. INTERNATIONAL TRANSFER

6.1. We mainly Process Personal Data in India. However, We may transfer Personal Data outside India for the purposes referred to in Section 4. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.

6.2. If You are a resident of the European Economic Area and when Your Personal Data is Processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

  1. RETENTION OF PERSONAL DATA

7.1. We retain the Personal Data that has been collected by Us for as long as it is required for a legitimate business purpose.

7.2. In the absence of a need to retain Personal Data under Section 7.1. above, We will either delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible. 

7.3 Customer Data that has been Processed by Scribble Data in relation to the Customer’s use of Scribble Enrich shall be retained for as long as required and in such manner as has been specified in the License Agreement or as instructed by the Customer in writing.

  1. SECURITY OF PERSONAL DATA

    We use appropriate technical and organizational measures to protect the Personal Data that We collect and Process. The measures We use are designed to provide a level of security appropriate to the risk of Processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us immediately as described in this Policy.

  1. YOUR RIGHTS

    You are entitled to the following rights:

9.1. You can request Us for access and correction of Your Personal Data.

9.2. If We have collected and Processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any Processing We have conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

9.3. You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority.

9.4. You have the right to opt-out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails We send You. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact Us.

9.5. If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights:

9.5.1. You can request Us for deletion and erasure of Your Personal Data.

9.5.2. You can object to the Processing of Your Personal Data, ask Us to restrict processing of Your Personal Data or request portability of Your Personal Data.

9.6. If You seek to exercise Your rights under this clause, please contact Us at the details provided in clause 13. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

  1. COOKIE POLICY

10.1. Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behavior information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customize the Website(s) for You or to make advertising messages more relevant to You.

10.2. Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

10.3. Analytics, Customisation and Advertising Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

10.4. When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

  1. PRIVACY OF CHILDREN

11.1. We recognize the importance of children’s safety and privacy. We do not request, or knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to us at the email address provided in clause 13.

  1. USE OF SCRIBBLE ENRICH BY CUSTOMERS AND END-USERS 

12.1. This Privacy Policy does not apply to any information that we Process on behalf of Customers or End-Users in relation to the use of Scribble Enrich. Our use of such information is governed by our License Agreement, which covers access to and use of the Scribble Enrich platform and any other products or services covered under the License Agreement. 

12.2. The security and privacy practices, including how We protect, collect and use Customer Data are detailed in and governed by our License Agreement or such other applicable agreement between the Customer and Us relating to the access and use of Scribble Enrich. Other than the Personal Data of Users of Scribble Enrich collected under clause 2 and for the applicable purposes set forth in clause 4 for which Scribble Data shall act as the Controller, for any other Processing of Personal Data collected from a User, Scribble Data will only act as a Processor and such Processing will be governed by the License Agreement.

12.3. Scribble Enrich is intended for use by enterprises. Where Scribble Enrich is made available to an End-User by a Customer, that enterprise is the Controller of the End-User’s Personal Data. In such a case, the End-User’s data privacy questions and requests should be submitted to the Customer in its capacity as the End-User’s Controller. If the End-user is an individual who interacts with a Customer using Scribble Enrich, the End-User will be directed to contact Our Customer for assistance with any requests or questions relating to their Personal Data. We are not responsible for Customers’ privacy or security practices which may be different from this notice. Customers of Scribble Enrich are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Scribble Enrich by End-Users.

12.4. Our Website(s) contain links to other websites. Our Policy applies only to Our Website(s), so if You click on a link to another website, You should read their privacy policy. We encourage You to review the privacy statements of any such other websites to understand their Personal Data practices.

  1. CONTACT INFORMATION

    You may contact Our grievance redressal officer if You have any enquiries or feedback on Our personal data protection policies and procedures, or if You wish to make any request, in the following manner:

    Kind Attention: Privacy Officer
    Email Address: privacy@scribbledata.io
    Address: No. 2074 (#17), 16 D Main Road, H.A.L. 2nd Stage, Bangalore 560 008

  1. CHANGES TO THE POLICY

    We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time and You shall be notified only if there are material changes to this Policy.