Privacy Policy

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This privacy policy (“Policy”) applies to Riversys Technologies Pvt Ltd along with its affiliates Scrut Automation Inc herein called as Scrut Automation and was last updated May 2024. We may change or update this policy at any time, and the same will be updated here.  If you are a Scrut Automation user or customer, we shall notify the changes or updates either by sending an email or a notification on the Scrut Automation App (as defined below). Please ensure to read such notices carefully. We sincerely believe that you should always know what data we collect from you, the purposes for which such data is used, and that you should have the ability to make informed decisions about what  you want to share with us.  Therefore, we want to be transparent about: (i) how and why we collect, store and use your personal data in the various capacities in which you interact with us; and (ii) the rights that you have to determine the contours of this interaction. While we would strongly advise you to read the Policy in full, the following summary will give you a snapshot of the salient points covered herein:

• This Policy details the critical aspects governing your personal data relationship with Riversys Technologies Private limited, having its registered office at 302, Plot No 15, 3rd Floor, Kumar Tower, Wazirpur Industrial Area, Delhi North-West, 110052, and its subsidiary, Scrut Automation, Inc., a company incorporated under the laws of United States of America, and having its registered office at 691 S Milpitas Blvd, Suite 217, Milpitas, CA 95035 USA (collectively, Scrut Automation);

• Your personal data relationship with Scrut Automation varies based on the capacity in which you interact with us/avail of our products and solutions (“Services”). You could be: (i) a visitor to https://www.scrut.io/  (“Website”) or any pages thereof (“Visitor”); (ii) a person/entity availing of one of our Services (“Customer”); or (iii) an employee/agent/representative/appointee of a customer who uses the said Service (“User”);

• Based on whether you are a Visitor, Customer or User, the type of data we collect and the purpose for which we use it will differ and this Policy details such variations;

• This Policy is a part of and should be read in conjunction with our https://www.scrut.io/terms-of-use ; and

• This Policy will clarify the rights available to you vis-à-vis the personal data you share with us.

If you have any queries or concerns with this Policy, please contact our Grievance Officer (refer Section 12). If you do not agree with the Policy, we would advise you to not visit/use the Website or the Scrut Automation application(s)/platform(s) (collectively “App”).

TYPE OF USER	VISITOR	CUSTOMER	USER
WHAT DATA WE MAY COLLECT	Your location;  How you behave on the Website, (what pages you land on, how much time you spend, etc.); What device you use to access the Website and its details (model, operating system, etc.); Cookies and Web Beacon data Name; and e-mail.	1. The name and e-mail of your representative who signs up for a Service on your behalf; and 2. Credit Card/ Debit Card/Other Payment Mode information to check your financial qualifications, detect fraud and facilitate payments for our Services.	Your name, e-mail; How you behave in the relevant product environment and use the features; What device you use to access the Website/App and its details (model, operating system, etc.); Cookies and Web Beacon data;
HOW AND WHY, WE USE IT	We use this information to analyse and identify your behaviour and enhance the interactions you have with the Website. If you submit your details and give us your consent, we may send you newsletters and e-mails to market other products and services we may provide.	We collect this data in order to help you register for and facilitate provision of our Services. We also use this data to enable you to make payments for our Services. We use a third-party service provider to manage payment processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of payment processing on our behalf. If you give us your consent, we may send you newsletters and e-mails to market other products and services we may provide.	We collect this data in order to facilitate provision of our Services. We will occasionally send you e-mails regarding changes or updates to the Service that you are using. In the event you report an issue with a Service, we may also screen/video record your device only when you use the App for a limited time period to help us better understand how to address the issue. If you give us your consent, we may send you newsletters and e-mails to market other products and services we may provide.

Information transferred via the Google API: Scrut’s use and transfer of information received from Google API’s to any other app will adhere to Google API Services User Data Policy, including Limited Use requirements.

FOR THE AVOIDANCE OF ANY DOUBT, WE SHOULD CLARIFY THAT IN THE EVENT WE ANONYMIZE AND AGGREGATE INFORMATION COLLECTED FROM YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER APPLICABLE LAW.

Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time, here.

Subject to the GDPR and applicable law’s limitations, the rights afforded to you as a data subject are:

1. RIGHT TO BE INFORMED : You have a right to be informed about the manner in which any of your personal data is collected or used which we have endeavored to do by way of this Policy.
2. RIGHT OF ACCESS : You have a right to access the personal data you have provided by requesting us to provide you with the same.
3. RIGHT TO RECTIFICATION : You have a right to request us to amend or update your personal data if it is inaccurate or incomplete.
4. RIGHT TO ERASURE : You have a right to request us to delete your personal data.
5. RIGHT TO RESTRICT : You have a right to request us to temporarily or permanently stop processing all or some of your personal data.
6. RIGHT TO OBJECT : You have a right, at any time, to object to our processing of your personal data under certain circumstances. You have an absolute right to object to us processing your personal data for the purposes of direct marketing.
7. RIGHT TO DATA PORTABILITY : You have a right to request us to provide you with a copy of your personal data in electronic format and you can transmit that personal data for using another third-party’s product/service.
8. RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING : You have a right to not be subject to a decision based solely on automated decision making, including profiling.

In case you want to exercise the rights set out above you can contact our Grievance Officer whose details are set out in Section 12 below.

The data provided by you as a Visitor, or when you sign up as a Customer / User or register for our Services will be processed by us for the purpose of rendering Services to you or in order to take steps prior to rendering such Services, at your request. Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time here.

Additionally, we may process your data to serve legitimate interests.

Accordingly, the grounds on which we can engage in processing are as follows:

NATURE OF DATA	GROUNDS
Visitor Data	Consent; Performance of a Contract; and Legitimate Interest Performance of a Contract; and Legitimate Interest
Account Registration Data
	Compliance with applicable laws; Legitimate Interest
Service Usage Data	Performance of a Contract; and Legitimate Interest
Data for Marketing our Services	Consent; and Legitimate Interest

If you believe we have used your personal data in violation of the rights above or have not responded to your objections, you may lodge a complaint with your local supervisory authority. Additionally, please note:

• If you are a Customer/User using one of our Services to collect data about an EU data subject from third parties, it shall be your sole obligation to inform such data subject about the source of such data; and
• We do not collect any Special Categories of Personal Data. Further, if you are a Customer/User, you hereby agree and acknowledge that you shall not, under any circumstances, whether directly or indirectly, use our Services to collect or process Special Categories of Personal Data or transfer to us any such data.
• The term “Special Categories of Personal Data” shall have the meaning ascribed to it under the GDPR and shall include, without limitation, data pertaining to a data subject’s race, ethnic origin, genetics, political affiliations, biometrics, health or sexual orientation.

Scrut Automation complies with CCPA by giving you the five privacy rights for California consumers:

1. The right to know about the personal information a business collects about them and how it is used and shared
2. You have a right to be informed about the manner in which any of your personal data is collected or used which we have endeavored to do by way of this Policy.
3. The right to delete personal information collected from them.
4. Scrut Automation gives you the right to request us to delete your personal data.
5. The right to opt-out of the sale of their personal information.
6. The right to non-discrimination for exercising their CCPA rights.

Scrut Automation does not sell any data of any of its users/customers/leads. Scrut Automation assures no discrimination against consumers exercising their right of privacy under CCPA. Scrut Automation assures that it will not ask for waiver of privacy rights from California consumers. In case you want to exercise the rights set out above you can contact our Grievance Officer whose details are set out in Section 12 below. Scrut Automation adheres to the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules) to ensure your data is secure. Here’s how Scrut Automation complies with the SPDI Rules:

The right to be informed and give consent	Before Scrut Automation collects any of your personal data, we will clearly explain what information we need, why we need it, and how we will use it. We will only collect your personal data with your explicit consent.
The right to access your data	You have the right to request access to the personal information Scrut Automation holds about you. This includes the ability to review and verify its accuracy and completeness.
The right to correct mistakes	If you find any errors or missing information in your data held by Scrut Automation, you have the right to request corrections. We will take reasonable steps to update your information promptly upon verification of your request.
The right to withdraw consent	You can withdraw your consent for Scrut Automation to process your sensitive personal data at any time. Once you withdraw consent, we will stop using your data for the purpose originally agreed upon, unless there’s a legal reason for continued processing (like a court order). To withdraw consent, please click (here)

Please contact our Grievance Officer, whose details are presented in Section 12, if you would like to exercise the rights listed above. We will store any personal data we collect from you as long as it is necessary in order to facilitate your use of the Services and for ancillary legitimate and essential business purposes – these include, without limitation, for improving our Services, attending to technical issues, and dealing with disputes. We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with our legal obligations, resolve disputes and enforce our agreements. If you are a customer, please be advised that: (i) you will need to inform your Leads about how you store and deal with any data you collect from them using one of our Services, in compliance with applicable laws including the GDPR; and (ii) after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you from our servers. If you are a Customer, you are empowered to use proprietary or other third party technologies and integrate with our App. If you do, you agree and acknowledge that it is your sole obligation to inform your stakeholders about any data you collect by using such technologies and the policies by which such collection is bound. In order for us to facilitate our operations, we may transfer and store the data we collect and process in accordance with this Policy, to our database server in a third-country for Disaster Recovery purpose. Your rights and protections will, under no circumstances, be diluted by this transfer. Further, in the ordinary course of business, we may employ other companies and people to assist us in providing certain components of our Services in compliance with the provisions of this Policy. To do so, we may need to share your data with them. Where applicable – if the entities to which these transfers are affected are not situated in countries deemed ‘adequate’ by the European Commission, we shall enter into appropriate Data Protection Addendums with the transferee parties that comprehensively protect your data. We shall also put in place industry-standard technical and organizational measures (including robust data handling policies) to ensure that such transfers are completed in accordance with applicable laws. Some of the examples of where we may sub-contract processing activities to third parties include—data analysis, marketing assistance, processing credit card payments, and providing customer service. In addition to the purposes set out in the Policy, we may disclose any data we collected or processed from you if it is required:

• Under applicable law or to respond to a legal process, such as a search warrant, court order, or subpoena;
• To protect our safety, your safety or the safety of others or in the legitimate interest of any party in the context of national security, law enforcement, litigation, criminal investigation or to prevent death or imminent bodily harm;
• If required in connection with legal proceedings brought against Scrut Automation, its officers, employees, affiliates, customers or vendors; or
• To establish, exercise, protect, defend and enforce our legal rights.

We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction or disclosure. When we collect particularly sensitive data it is encrypted using industry-standard cryptographic techniques including but not limited to SSL, TLS, RSA, and AES. We adhere to the ISO/IEC 27001:2022 standard, an internationally recognized framework for Information Security Management Systems (ISMS). Our commitment to ISO 27001 ensures that we follow rigorous security practices and maintain high standards for information security.  In compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, we adhere to the following reasonable security practices and procedures to protect your personal data:

Access Control	We ensure that access to personal data is granted only to authorized personnel on a need-to-know basis and that such access is logged and monitored.
Data Encryption	Sensitive personal data is encrypted both in transit and at rest using strong encryption methods such as AES-256.
Network Security	We employ secure network architecture, including firewalls and intrusion detection systems, to prevent unauthorized access.
Regular Audits	We conduct regular security audits and assessments to identify potential vulnerabilities and ensure compliance with our security policies.
Incident Management	We have established protocols for managing and responding to security incidents, including data breaches, to mitigate any potential impact on your personal data.
Employee Training	We conduct regular training programs for our employees to ensure they are aware of and comply with our security policies and procedures.
Third-Party Compliance	We ensure that any third-party service providers who handle personal data on our behalf adhere to equivalent security standards and practices.
Physical and Environmental Security	We have implemented robust physical security controls to protect our data centers and other facilities from unauthorized access, damage, and interference.
Business Continuity Management	We have developed and tested business continuity plans to ensure the availability of critical information and systems in the event of a disruption.
Risk Assessment and Treatment	We conduct regular risk assessments to identify potential security threats and vulnerabilities, and implement appropriate risk treatment plans to mitigate identified risks.
Audit and Compliance	We conduct regular internal and external audits to ensure compliance with ISO 27001 standards and continuously improve our ISMS.

The name and contact details of our Grievance Officer, who you may contact if you have any concerns, complaints or feedback pertaining to this Policy, are as follows:

ADDRESS:	Scrut Automation, Indiqube Ascent 420, Mahakavi Vemana Road, KHB Block Koramangala, Koramangala 4-B Block, 5th Block, Koramangala, Bengaluru, Karnataka 560034
EMAIL:	privacy@scrut.io