Scrub AI Holdings Limited (Scrub AI, we, us) take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws including the General Data Protection Regulation (GDPR-EU and GDPR-UK).
This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information below.
Personal Information is any personal identifiable information, such as your email address, name, home or work address, telephone number, bank details or online identifier, which can directly or indirectly identify you.
Why we collect your personal information
We collect your personal data for one of the following purposes:
To meet our contractual obligations to a client
Where we need to perform the contract we have entered into with you
To manage communications between you and us
To process payments
To provide you with information you have requested, or which we may feel may be of interest to you
To ensure the safe operation of our website and to monitor the performance of our website
For marketing and advertising purposes
Lawful basis of processing information
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:
The data subject (you) has given consent to the processing activity taking place
If the processing is necessary for the performance of a contract with you
If the processing is necessary for the performance of a contract with a Data Controller to whom you have provided your personal data
If the processing is necessary for compliance with a legal obligation
If the processing is necessary for the purpose of the legitimate interest pursued by us or our partners.
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three- part test covering:
The purpose test – to identify the legitimate interest
Necessity test – to consider if the processing is necessary for the purpose identified
Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.
What information we collect and where from
We collect personal information from you, for example, if you register to our website, use the website, provide information on the website, request product information, call us (your call may be recorded), email us, interact with us on social media or use any of our services. The personal information that we may collect, store and use about you may include:
Transactional information about the services you use and how you interact with us and the services e.g. services viewed, page response times, download errors, length of visit, scrolling, clicks and mouse overs
We may use technologies, such as tracking pixels to collect some of the above information from emails we send you. This helps us to focus our marketing to your requirements and provide more relevant emails to you. It also helps us to identify if you are not engaged with our marketing emails.
How long we keep information for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Security of personal information
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place appropriate technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.
We have ensured that all employees have had information security and data protection training.
Unfortunately, the transmission of information via the Internet is not completely secure so we cannot guarantee the security of your information when it is transmitted to our website or from third party websites, any transmission is at your own risk, however we use strict procedures and security features to prevent unauthorised access.
The site may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, we cannot accept any responsibility or liability and you will have to agree to such company’s privacy notice. Please ensure you agree to such policies before submitting your personal data.
We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party, but we may share information with our service providers for the purposes set out in this Privacy Notice. We will keep your information confidential and protect it in accordance with our Privacy Notice and all applicable laws.
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details provided below so we can remove this information without any undue delay.
Your individual rights
In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are the:
Right to Object
Right of Access
Right to be informed
Right to Rectification
Right to Erasure
Right to Restrict Processing
Right to Data Portability
The right to object
You can exercise this right if:
Processing relies on legitimate interest
Processing is for scientific or historical research
Processing includes automated decision making and profiling
Processing is for direct marketing purposes
The right of access
You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
The right to be informed
We are required to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
The right of rectification
If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
The right to erasure
If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
The right to restrict processing
You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
Processing is unlawful
We no longer need the personal data, but it is required for a legal process
You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
If you are exercising your right to rectification
The right to data portability
You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
Processing is based on consent
Processing is by automated means (i.e. not paper based)
Processing is necessary for the fulfilment of a contractual obligation
If you have any question about these rights, please see “additional information” below.
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
Failure to provide personal information
Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
Automated decision making
Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement).
Transfers to third parties
We may disclose the personal data listed above to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
Government agencies such as HMRC
Third parties that support us to provide products and services e.g. IT support, hosting providers, cloud-based software services, providers of telecoms equipment
Marketing/PR services providers
Payment service providers
Recruitment service providers
Professional advisors e.g., lawyers, auditors, bankers
Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.
Transfers outside of the UK/EEA
Some of the recipients with whom we may share personal and special information may be located in countries outside of the UK and, in some cases, outside the European Union and/or European Economic Area (the EU and EEA). Recipients within the EU or EEA and some countries outside these areas are deemed to have an adequate level of protection for this data and we do not need to put in place additional safeguards.
For transfers to entities outside of the EU or EEA that are not deemed adequate, transfers will be bound by the International Data Transfers Agreement (IDTA) and the Addendum to the EU SCCs (the Addendum), to ensure that your data is protected adequately. In addition, we will undertake a transfer risk assessment (TRA).
Right to complaint
If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO):
By Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
By Phone: 0303 123 1113 (local rate) or 01625 545 745 (National rate)
Please do contact us using the following details in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position.
By writing to: Scrub AI Holdings Limited, 84 Dagnan Road, London, England, SW12 9LQ
Policy review and amendments
We keep this Policy under regular review. This Policy was last updated on 01 Dec 2022
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.