PRIVACY POLICY

1. INTRODUCTION

Pink Cow Media Ltd (hereinafter the “Company or “we”), owner of the website scribba.com (the “Site”), respects your privacy and is committed to protecting your personal data.

  • the Site, once you access the website and become a user; and
  • any of the services accessible through the Site, as such are described in the Terms of Use (the “Services”).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This privacy policy:

  • provides an overview of how we collect, process and protect your personal data, including sensitive data;
  • informs you about your rights under the General Data Protection Regulation 2016/679 (GDPR) and any national law supplementing or implementing the GDPR (jointly with the GDPR, the “Privacy Laws”);
  • contains important information about what personal data we collect, what we do with such personal data, who we may share it with and your rights in relation to the personal data you have given us.

For the purposes of this privacy policy:

  • When we refer to “personal data” or “personal information” we mean data which identifies or may identify you and which may include, for example, your name, address and telephone number. It does not include data where your identity has been removed (anonymous data).
  • When we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data.
  • When we refer to “sensitive data” we mean special categories of personal data which identify or may identify you and which may reveal, inter alia, details about your racial or ethnic origin, your political opinions, your religious or philosophical beliefs, your trade union memberships, your health, your sex life or your sexual orientation.
  • When we refer to “users” we mean individuals who have accessed the website even if they didn’t sign-up on the Site.
  • When we refer to “Account” we mean the account you create on the Site following completion of the sign-up process.


2. WHO WE ARE

Pink Cow Media Ltd, who owns, operates and manages the Site, is the controller and is therefore responsible for your personal data.

The Company takes the protection of your personal data very seriously. If you have any questions or concerns regarding the collection and processing of your personal data by us or if you wish to exercise any of your rights (as set out in section 9 of this privacy policy), please do not hesitate to contact us using the details set out below and we shall be happy to provide you with a response as soon as possible.

  • Email address: support@scribba.com
  • Postal address: 2 Dervenion 4th floor Agios Antonios, 1055 Nicosia Cyprus


3. HOW WE COLLECT YOUR PERSONAL DATA

We collect your personal data from various sources, as follows:

a) Personal data collected directly from you. This is information you submit to us directly by using the Site or by corresponding with us (for example, by email or phone). It includes information you provide when you:

  • create an Account and complete your profile with details about yourself and your preferences, and when you use the Services of the Website;
  • request marketing to be sent to you;
  • enter a competition or promotion run on the Site; and
  • report a problem to us in connection with the Site or the Services or when you contact us for any other reason. If you contact us, we will keep a record of that correspondence.

b) Automated technologies or interactions. Each time you access the Site and interact with it, we will automatically collect data in connection to your equipment, browsing actions and patterns. We store this data by using cookies and other similar technologies. We may also collect data about you if you visit other Sites employing tracking technologies.

c) Third parties. We will receive personal data about you from various third parties as set out below:

  • Analytics providers (such as Google);
  • Advertising networks;
  • Service providers;
  • Affiliated companies who send us your sign-up details directly to facilitate the registration process on the Site;
  • Other service providers who assist us in mitigating the risks of fraudulent activity on the Site by, for example, checking whether the email you have given us is valid and/or the payments you have made are through your own credit card and/or your own funds.


4. THE DATA WE COLLECT ABOUT YOU

We may collect and process the following personal data about you:

  • Identity Data including your username or similar identifier, your date of birth, your age, your gender as well as your country and city of residence. In cases where you provide us with a government issued identification document (such as an ID, driver’s licence or passport) so that we can verify your identity, we will additionally collect any other details contained in the identification document you provide to us.
  • Contact Data including your e-mail address.
  • Account and Profile Data including your username and password and information you voluntarily include in your Account.
  • Classification Data assigned by the Site to users such as whether you are a new user or a verified user, including the steps you have taken (if any) to verify your Account.
  • Technical Data including your internet protocol (IP) address, your browser type and version, details of your device, your time zone setting and location, and your operating system and platform.
  • Usage Data including information collected through cookies, such as the links you have clicked on (including date and time), services you viewed or searched for, page response times, download errors, what time you accessed the Site, length of visits to our webpages, page interaction information (such as scrolling and clicks), and methods used to browse away from our Site.
  • Marketing and Communications Data including your preferences in receiving marketing from us and third parties with which we partner from time to time, as well as your communication preferences (i.e. whether you wish to receive such marketing through email, SMS, push notifications, system messages, or otherwise).
  • Records of any correspondence and/or communications we have with you, such as when you contact us to report an issue with your use of the Site and/or the Services.
  • Sensitive Data that you may have disclosed voluntarily on your Account (if such an option exists).

We may also collect, share, and use Aggregated Data such as statistical data for any purpose. Aggregated Data could be derived from personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users using a specific Site feature. 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.


4.1 Signup via Google 

If you would like to sign up easier, you can use the Google services. The account you have with Google will also give you access to our service. For the use of these services, the data privacy policy of the corresponding provider applies in the first instance (Google data privacy policy) as well as any additional agreements you have consented to as a customer of Google. In this regard, please refer to the respective data privacy policies of Google and check the agreements you have consented to in conjunction with these contracts or separately.

Google will transfer the following personal data regarding you, which we will store on our secure servers.

  • First Name and Last Name
  • Email Address
  • Verification status of the Email Address


5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Where you have provided your explicit consent before the processing. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us using the contact details set out in section 2 of this privacy policy or through the opt-out options available on your Account or in email communications we send you.
  • Where we need to comply with a legal or regulatory obligation that we are subject to, such as for example a tax obligation.

We provide further details in connection to each legal basis on which we rely, as follows:

Performance of a contract

When you access the website and have therefore become a user, we will process your personal data in order to:

  • provide you with the Services, and
  • manage our relationship with you in accordance with the Terms of Use, including notifying you of changes to the Site or the Services (including changes to this privacy policy and/or the Terms of Use) and liaising with you to resolve any issues or concerns you may have. You may select to receive notifications relevant to the Services via email, SMS, push notifications, or through the Site and can amend the way in which you receive them at any time through the settings on your Account.

Where we need to collect personal data under the terms of the contract we have with you, and you fail to provide that data when requested, we may not be able to provide you with the Services (either partly or fully).

Legitimate interests

We may process your personal data on this basis in order to:

  • administer and protect our business, including the Site, and develop our Services. To this end, we may keep track of any contact we have with you, including through phone calls, email, chat, or through other forms of communication. Records of such communications will assist us in checking your instructions to us (or vice versa) and assessing, analyzing, and improving the Services and training our people;
  • manage the security of our network and information systems (including troubleshooting, testing, system maintenance, support, and hosting of data);
  • perform data analytics (such as market research, trend analysis, financial analysis, and customer segmentation) to improve our services marketing, customer relationships, and experiences;
  • identify, prevent, and investigate fraud by addressing ongoing or alleged breaches of the Terms of Use and by collaborating with service providers, developing countermeasures against fraudulent activities and retaining data of past fraudulent behaviors to prevent recurrences;
  • maintain our accounts and records;
  • receive professional advice (e.g. tax or legal advice);
  • defend, investigate, or prosecute legal claims;
  • enable you to participate in a competition or complete a survey;
  • enable a sale, reorganization, transfer, or other transaction relating to our business, and
  • provide you with information about other services, events, and offers that may be available on the Site from time to time.
Legal obligation

In certain cases, we may need to retain your personal data to comply with our legal obligations. Examples include:

  • When we need to contact you to deliver mandatory communications required by any new law that comes into force;
  • When we need to investigate certain fraudulent activities and/or any business disrupting incidents for which we are required to prepare relevant reports for the relevant supervisory authorities;
  • When we need to manage any legal claims connected to users’ use of the Site and/or the Services, and/or
  • When we need to comply with our tax obligations.
Consent

We will only request your consent in the circumstances described below.

  • SPECIAL CATEGORIES OF PERSONAL DATA

When we obtain details of your race or ethnicity through the identification document you may provide to us. We will not use such information in any way, but we will securely store it on our systems in accordance with our retention policy. We will request your prior consent before or upon your provision of these types of personal data to us.

When you voluntarily provide details of your sexual orientation or when you reveal information in connection with other sensitive data. We will request your prior consent before or upon your provision of these types of personal data to us.

  • THIRD PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes and/or before we provide you with any information in connection to offers or promotions of third parties.

  • OPTING OUT

You can ask us to stop sending you marketing messages at any time by logging into the Site and adjusting the relevant marketing preferences on your Account or by following the opt-out links on any marketing message sent to you or by contacting us using the contact details in section 2 above.


6. WITH WHOM WE MAY SHARE YOUR PERSONAL DATA

We may share your personal data with third parties as listed below for the purposes set out in section 5 above. When we do so, we request from such third parties to have appropriate technical and organizational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the purposes described in this privacy policy.

  • Service providers who provide us with services including but not limited to:
    • IT and system administration services,
    • customer support services,
    • marketing services, and
    • payment solutions services.
  • Professional advisers including lawyers, bankers, auditors, tax consultants, and insurers who provide consultancy, banking, legal, tax, insurance, and accounting services.
  • Tax authorities, regulators, and other governmental bodies or agencies who may require reporting of our processing activities in certain circumstances.
  • Advertisers and marketing affiliates who assist us in advertising the Site and who help us drive traffic to it.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners will use your personal data in the same way as set out in this privacy policy.
  • Other third parties for which we will seek your consent prior to any disclosure. This may include, for example, third parties who may wish to advertise their products to you.


INTERNATIONAL TRANSFERS


Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use specific service providers or share your personal information with third parties, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.


7. SAFEGUARDING YOUR DATA

All information you provide to us is stored on our secure servers.

We perform regular vulnerability scans to ensure that our systems and servers remain secure and require that our payment-processing providers take the same measures to ensure stability and security of their own servers as well.

We additionally have in place Secure Socket Layers to ensure that all communications carried out through the Site are secure.

Where we have given you (or where you have chosen) a password for your Account, you are responsible for keeping this password confidential. Please do not share it with anyone.

We and our business partners do our utmost to protect your personal data in line with the prevailing data protection regulations by means of physical, electronic, and process-oriented security precautions. However, we cannot guarantee 100% protection against unauthorized access from third parties. When we do become aware of such unauthorized access, we immediately take all steps necessary to block such third party from retrieving, accessing, or otherwise compromising any personal data and ensure that any risks to our users are mitigated.

If at any time you suspect or become aware of a breach of your Account or if you believe that your information is no longer secure, please contact us immediately using the contact details in section 2 of this privacy policy, so that we can take any necessary action.


8. HOW LONG WE KEEP YOUR PERSONAL DATA

To determine the appropriate retention period for your 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.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you have tried to register as a user on the Site but have been unsuccessful (due to the fact that you have not provided us with all the information we have requested or you are not eligible to become a user or for any other reason), we will delete any personal data you have provided to us during the registration procedure immediately following your unsuccessful attempt to register.


9. YOUR LEGAL RIGHTS

You have the following rights in terms of the personal data and information we hold about you:

  • Receive access to your personal data

    • This enables you to receive a copy of the personal data we hold about you and to be informed on how we are lawfully processing it.

  • Request correction of the personal data we hold about you

    • This enables you to have any incomplete, inaccurate, or out-of-date information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data

    • This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below) or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal or contractual reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data

    • You can object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request the restriction of processing of your personal data

    • This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data's accuracy;
    • Where you consider that our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • The right to ‘data portability’

    • When you request a transfer of your personal data, we will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw your consent

    • In cases where you have given your consent to us, you will be able to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


10. HOW TO EXERCISE YOUR RIGHTS

To exercise any of your rights as set out in section 9, you can use the contact details set out in section 2 above.

For security reasons, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.

In some cases, such as when you wish to change or update your personal data, you may be able to do so by accessing your Account and making changes to the relevant fields that need to be corrected or updated.


11. THIRD PARTY LINKS

Our Site may, from time to time, contain links to and from the websites of our partner networks and/or advertisers. Please note that these websites and any services that may be accessible through them have their own privacy policies. We do not accept any responsibility or liability for these third-party privacy policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.


12. CHILDREN

We do not intend to solicit or collect personal data from anyone under the age of eighteen (18) or under the legal age in the jurisdiction in which they reside. If you are under the legal age in your jurisdiction, do not enter information on the Site or engage the Services. If you believe a child of yours under the legal age has entered personal data, please contact us using the contact details in section 2 above to have the data removed and terminate the child’s Account.


13. CHANGES TO OUR PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version of the privacy policy was last updated on 07.12.2022.

If we update our privacy policy in the future, the changes will be posted on this page and, where appropriate, notified to you either by email or when you next access the Site. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the Site or the Services.

We do, however, encourage you to review this policy periodically to stay informed about how we are processing and protecting your personal information.

It is important that the personal data we hold about you is accurate and current. Please keep us informed of your personal data changes during our relationship with you.