The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise to never sell your data: never have, never will.

This policy applies to all products built and maintained by Scramble ID, Inc. including “online”, “voice”, “badge”, “people”, “behavior” and any future products or services we develop. This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Scramble). We refer collectively to these categories of individuals as “you” throughout this policy.

However, this policy does not cover information about a customer’s end users that Scramble receives from a customer, or otherwise processes on a customer’s behalf, in connection with the services provided by Scramble to the customer pursuant to an applicable services agreement. Scramble’s obligations as a “data processor” or “service provider” with respect to such information are defined in such services agreement and applicable data protection addendum and are not made part of this policy. If you are a customer’s end user and you have questions about how your information is collected and processed through the services, please contact the organization who has provided your information to us for more information.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity & access

When you sign up for a Scramble product, we ask for identifying information such as your name, phone number, and email address. That’s so you can personalize your new account, and we can do the initial verification that you are in fact you (e.g., a bad actor isn’t trying to impersonate you). We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We may also give you the option to add a profile picture or other information that displays in our products. Net-net, we only ask for your data so we can protect you and personalize your experience. We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

If you purchase a Scramble product or service, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Scramble servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent transactions.

Product interactions

We store on our servers the content that you upload or receive or maintain in your Scramble product accounts. This is so you can use our products as intended, for example, to leverage the badging service with a picture of yourself or to receive email about new authentication features for online. We keep this content as long as your account is active. If you delete your account, we’ll delete the content within 60 days.

General geolocation data

For most of our products, we log a variety of data points used to sign up a product account and also each time you do an authentication from any of our services. We retain that for use in mitigating future spammy signups, fraud attempts, quality assurance, and bug fixes. We keep this attributable data for as long as your account is active.

Website interactions

We collect information about your Scramble ID website browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which Scramble ID web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active.

Anti-bot assessments

We use CAPTCHA across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your Scramble account and when you fill in certain forms, the CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides Scramble with the spam score results; we do not have access to the evaluated information.

Advertising and cookies

Scramble doesn’t do this today, but we may in the future run contextual ads on various third-party platforms such as Google, Reddit, and LinkedIn. Users who click on one of our ads will be sent to the Scramble site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form. We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics. A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off.

Voluntary correspondence

When you email Scramble with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future. We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

How we approach mobile app permissions

We offer optional desktop and mobile apps for some of our products. Because of how the platforms are designed, our apps typically must request your consent before accessing the camera and other privacy-sensitive features of your device. Consent is always optional, and our services may still work, though some features (potentially important ones) may be unavailable.

When we access or disclose your information

We use some third-party firms to help run our applications and provide the Services to you. We also use third-party processors for other business functions such as notifications, health checks, sending customer surveys, and providing help with our company website. We may disclose your information at your direction if you integrate a third-party service into your use of our products.

No Scramble human looks at your content except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see “When required under applicable law” below).

To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.

To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.

Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.

When required under applicable law. Scramble is a U.S. company and all data infrastructure are located in the U.S.

• Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if U.S. law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside the U.S. if compelled by the U.S. government through procedures outlined in a mutual legal assistance treaty or agreement. It is Scramble’s policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.
• Preservation requests. Similarly, Scramble’s policy is to comply with requests to preserve data only if compelled by the U.S. Federal Stored Communications Act, 18 U.S.C. Section 2703(f), or by a properly served U.S. subpoena for civil matters. We do not disclose preserved data unless required by law or compelled by a court order that we choose not to challenge. Each preserved data request is assigned to legal counsel for evaluation.
• Civil matters. We may disclose account information to third parties in limited circumstances for the purposes of civil legal proceedings, such as the name and billing address of a customer when required by law to comply with a valid court order. Unless legally prohibited, we notify affected customers before disclosing this information.

Your rights with respect to your information

At Scramble, we apply the same data rights to all customers, regardless of their location. Some of these rights include:

• Right to Know. You have the right to know what personal information is collected, used, shared, or sold. We outline both the kinds of data we collect and how we process it in this policy.
• Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security, and processing of that information.
• Right to Correction. If you believe that personal information we hold about you is incorrect, you have the right to request that we correct or amend the information.
• Right to Deletion / Erasure. This is your right to request, subject to certain limitations under applicable law, that your personal information is erased from our possession (right to be forgotten). Fulfillment of some data deletion requests may prevent you from using Scramble services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
• Right to Complain. You have the right to submit a complaint to Scramble or your data protection authority.
• Right to Restrict Processing. This is your right to request the restriction of how and why your personal information is used or processed.
• Right to Object. This is your right, in certain situations, to object to how or why your personal information is processed.
• Right to Portability. This is your right to receive the personal information we have about you and the right to transmit it to another party.
• Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a significant legal effect on you from being made solely based on automated processes. We don’t use any such automated processes.
• Right to Non-Discrimination. This right stems from the California Consumer Privacy Act and states that you can exercise all these rights at any time, and we will not discriminate against you, in any form, for exercising these rights.

Many of these rights can be exercised by contacting us at support@scramble.id or by accessing your Scramble account and checking various settings. If you need further assistance, you can contact us at support@scramble.id, and we will respond to your request within 30 days. If we need to extend the time or are unable to fulfill your request, we will let you know why and provide an explanation.