We recognize privacy is important to our users. This document describes how and why Scramble ("we", "us" or "our"), collects, receives, possesses or stores Personal Information (as defined below) as well as non-personally identifiable data from users and website visitors, publishers, mobile applications and end users of publisher sites to Scramble ("you"/ "your"), and how that data will be used, handled, dealt with and shared with third parties ("Privacy Policy/Policy"). Scramble is committed to respect the privacy of personal information as well as non-personally identifiable data.
We urge you to read the Policy carefully in order to gain a clear understanding of the type of Personal Information collected and how we may collect the same, usage or disclosure of your Personal Information in the course of providing you with our products or services, and your use of our mobile application Scramble as well as reasonable security practices and procedures adopted for the collection and usage of your Personal Information. Your information is collected mainly vide two means: (i) information supplied by you or (ii) automatic retention of your data during the navigation of Scramble by you.
This Privacy Policy covers the following:
"Personal Information" means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information.
This Policy does not cover anonymized aggregated data from which the identity of an individual cannot be determined. Scramble reserves the right to use anonymized data in any way it determines appropriate.
We may collect the following Personal Information when you visit our Portal, contact us, register with us, use our products or services or otherwise provide us with information about you and use the same in accordance with the terms of this Privacy Policy:
We obtain certain information about your use of our Portal. This information is collected when publishers, advertisers, and advertisement networks use the Scramble platform. Additionally, certain other information (such as cookies, described below) may be transmitted by our web server to your computer. Specific types of usage information that may be collected automatically are described below:
We may collect information from the users as a matter of compliance with the mandate of the laws that are applicable to us.
Scramble only collects Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing our products, services or Portal. We use only fair and lawful methods to collect Personal Information.
When you provide Scramble with the Personal Information, we ask for your express consent to us collecting it and using it for that specific purpose only.
If we ask for your Personal Information for a secondary reason, for e.g. marketing, we will ask you again for your express consent. In either case, we will provide you with an opportunity to say no. We will not share your Personal Information with any third party (other people or businesses) without your prior consent.
If after you opt-in, you change your mind, you may withdraw your consent for the continued collection, use or disclosure of your information, at any time, by contacting Scramble and intimating us of the same in writing.
However, please note that consent cannot be withdrawn retroactively. It should be noted that in certain circumstances, our products or services can only be offered if you provide us with your Personal Information.
Consequently, if you choose not to provide us with the required Personal Information, we may not be able to offer you these products or services. We will inform you of the consequences of the withdrawal of consent.
We use cookies to collect usage information when you visit our Portal and to serve advertisements to you. Cookies are small text files placed on your hard drive that assist us in providing a more customized Portal experience. It is our policy to use cookies to make navigation of our Portal easier for visitors.
If you are concerned about cookies, most browsers permit individuals to decline cookies. To learn how you may be able to reduce the number of cookies you receive from us or disable cookies that have already been installed in your browser's cookie folder, please refer to your browser's help menu or other instructions related to your browser
You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers. Note that while declining cookies may negatively affect your user experience on our Portal, however it will not prevent us from transacting with you.
In order to properly manage our Portal, we may anonymously log information on our systems, and identify categories of visitors by items such as domains and browser types. These statistics are used to manage the operational efficiency of our systems.
As part of our ad delivery and reporting, we log page views and collect information for the purpose of delivering advertisements or providing advertising-related services, including providing a specific advertisement based on a particular type of browser or time of day; statistical reporting in connection with the activity on a website; and tracking the number of advertisements served on a particular day to a particular website (tracking web analytics data). To do so, we collect information about the type of browser, referrer and operating system of website visitors, as well as the domain name, day and time of visit, and page(s) visited. We do so across multiple web domains owned or operated by different entities.
Scramble uses the data collected from you and Portal visitors, including Personal Information, in order to:
We may also use statistical or aggregated information about the Portal's use and share, publish, post, disseminate, transmit or otherwise communicate or make available such information, to suppliers, business partners, sponsors, affiliates and any other third party, at our sole discretion.
We use push notifications to send you periodic alerts when we publish important and/or sponsor-related news items to the platforms. When you first enter our platforms, you may choose to approve or deny receiving push notifications. If you no longer wish to receive these notifications, you may turn them off at the browser or mobile device level
With respect to data collected via the Scramble platform, we may share such data with third parties, advertisers, and/or business partners anonymized, non-personally identifiable, or aggregated data we receive or collect. The use and disclosure of such anonymized, non-personally identifiable, or aggregated information is not subject to any restrictions under this policy.
Scramble may disclose the data collected from youusers and other Portal visitors, including Personal Information, to the following parties, provided that such disclosure shall be for the purposes which are related to the objectives for which such information is collected:
Provided however, our partners and service providers may change basis our commercial needs and requirements
The parties to whom the Personal Information is shared in accordance with the Paragraph 7 above, shall maintain the confidentiality of the same degree as we are subject to, and we shall undertake reasonable steps for ensuring that the information shared to the third-party (for the above mentioned purposes) is protected by the third-party, in accordance with the terms of this Policy document. Usually we do this by imposing contractual requirements on or seeking assurances from third-parties as to their compliance with our Privacy Policy
We keep your Personal Information only as long as it is required for the reasons for which such information it was collected. The length of time we retain Personal Iinformation varies, depending on the purpose for which it was collected and the nature of the Personal Iinformation. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. As such, we may retainkeep your account information after the termination of your account.
When your Personal Information is no longer required for the purposes for which it was collected, we will destroy, delete, erase or convert it into an anonymous form. If we learn that we have unintentionally stored Personal Information (e.g., if we become aware that a URL that we store contains Personal Information), we will use commercially reasonable efforts to anonymize or purge this information at the earliest.
Our Portal is analyzed on a regular basis for any security gaps and identified vulnerabilities for the purpose of securing the Personal Information collected and stored by us. Information that we collect is stored on servers that Scramble solely manages, using standard physical, procedural and technical security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification, or disclosure. The server is password protected and is strictly limited. We further protect Personal Information by restricting access to it on a need basis
However we cannot ensure or warrant the security of any information you transmit to Scramble , and you acknowledge that you do so at your own risk. We cannot guarantee that the information transmitted by you may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet, telephone or any other networks.
We do not favour any specific commercial product or service or any firm, trade name or corporation name which is used or referenced on our Portal. The reference of such is only limited to the informational purposes for the public.
We do not provide any direct or indirect representation or warranty with regard to the non-infringement of the third-party rights, title, merchantability, fitness and freedom of any computer virus in relation to the product or service provided vide this platform.
We shall not be held liable for any direct, indirect, incidental, compensatory loss, loss of goodwill, loss of income or profit or claims of third parties.
The information which is communicated vide a social media platform comes within the public domain and we do not guarantee the security of the same.
The user is advised to maintain the confidentiality of the login information which is provided by the user for registering with us. Such login information includes username and a password, which should be within the knowledge of the user only and should not to be disclosed to any other person.
The minimum age limit of the User to enter into any transaction in relation to the products and services offered by us, is 18 years. Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Scramble does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Scramble encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
A "breach of security safeguards" is defined as the loss of, unauthorized access to or unauthorized disclosure of Personal Information resulting from a breach of an organization's security safeguards or from a failure to establish those safeguards.
In case of a breach of security safeguards involving your Personal Information under our control, we will notify you in the circumstances to believe that the breach creates a real risk of significant harm to you, including physical, financial or reputational.
We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach. We will keep a record of all breaches in accordance with our legal obligations
Scramble endeavors to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary to the extent provided by you, for the purposes for which we use that information.
If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the Personal Information and, if necessary, use best efforts to inform third party service providers or contractors which were provided with inaccurate information so that those third parties may also correct their records. However, we shall not be held responsible for the authenticity of Personal Information as supplied by the user and we make no claim, guarantee or promise for the accuracy of the data and expressly disclaim any liability arising out of the inaccuracy in the content of information.
Scramble permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.
We reserve the right of refusal of the request for access of the Personal Information in certain circumstances including, where providing such access would be unlawful or where giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body. The refusal statement shall be conveyed to the individual in writing along with the reasons for such refusal and the appropriate grievance redressal mechanism for raising objections against the refusal.
Depending on the products, services or your use of our Portal, your choices may include the following:
We may provide links to, or automatically produce search results for, third-party websites or resources, or third-party information referencing or linking to third-party websites or resources. Scramble has no control over such third-party websites and resources, and you acknowledge and agree that Scramble is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Privacy Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. Scramble is not responsible for the privacy or security practices or the content of external websites, services or products.
Scramble cannot and does not guarantee, represent or warrant that the content or information contained in such third-party websites and resources is accurate, legal, non-infringing or inoffensive. Scramble does not endorse the content or information of any third-party website or resource and, further, Scramble does not warrant that such websites or resources will not contain viruses or other malicious code or will not otherwise affect your computer. By using Scramble 's Portal to search for or link to a third-party website, you agree and understand that Scramble shall not be responsible or liable, directly or indirectly, for any damages or losses caused or alleged to be caused by or in connection with your use of, or reliance on, Scramble to obtain search results or to link to a third-party website.
Scramble reserves the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Portal. If Scramble makes material changes to this Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. The continued usage of our platform shall be treated as a deemed acceptance to the modifications to the Privacy Policy, as and when such modifications are undertaken. If Scramble is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to be able to transact with you.
The Company shall on a best effort basis protect the Personal Data of its Users in the following manner, in addition to its statutory obligations as stated under Clauses 1 to 16 of the Privacy Policy.
"Personal Data" means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device, precise location data and biometric data.
We may tell you about the legal basis we're relying on to process any Personal Data about you
The legal basis for us processing your Personal Data for the purposes set out above will typically be because:As a general matter, we retain your Personal Data for as long as necessary to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally render our own identifiers (e.g., those we use to "sync" our customers data to online users) inactive after 13 months, provided that we may retain them if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.