Privacy Policy

Scrappy ("Scrappy", "we", "us", or "our") is a canvas-first workspace for capturing notes, voice memos, sketches, and ideas. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, applications, and services (collectively, the "Service").

If you have questions, email us at info@ei-digital.com.

We use your information to:

• Provide, maintain, and improve the Service;
• Create and manage your account;
• Process transactions and send related notices;
• Send product updates, security alerts, and support messages;
• Respond to comments and questions;
• Monitor and analyse usage trends to improve user experience;
• Detect, investigate, and prevent fraudulent or illegal activity;
• Comply with legal obligations.

We do not sell your personal information. We do not use your private content, including data obtained through Google Workspace APIs, to train or improve generalized artificial intelligence (AI) or machine learning (ML) models, except where you have explicitly consented and such use is permitted by applicable law and platform policies.

Where EU or UK data-protection law applies, we rely on the following legal bases:

• Contract — processing necessary to deliver the Service you signed up for.
• Legitimate interests — analytics, fraud prevention, and product improvement, balanced against your rights.
• Legal obligation — compliance with applicable law.
• Consent — marketing emails and optional analytics (you may withdraw at any time).

We share personal information only in these circumstances:

• Service providers — trusted vendors who process data on our behalf (hosting, payment processing, analytics, customer support) under strict confidentiality agreements.
• Business transfers — in connection with a merger, acquisition, or sale of assets, with advance notice to you.
• Legal requirements — when required by law, court order, or governmental authority.
• Protection of rights — to enforce our Terms of Service or protect the safety of our users or the public.
• With your consent — for any other purpose with your explicit permission.

We share personal information only in these circumstances:

• Where Scrappy accesses or processes data obtained through Google Workspace APIs, the use and transfer of raw or derived user data received from Google Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
• Google Workspace API data is accessed solely to provide the functionality requested by you. We do not use Google Workspace API data to develop, improve, or train generalized artificial intelligence (AI) or machine learning (ML) models, nor do we permit third parties to do so on our behalf, except as permitted under the Google API Services User Data Policy.

We use:

• Essential cookies — required for authentication and session management.
• Analytics cookies — to understand aggregate usage patterns (opt-out available in your account settings).

You can control cookies through your browser settings. Disabling essential cookies may impair the Service.

We retain your personal information for as long as your account is active or as needed to provide the Service. After account deletion, we delete or anonymise your data within 90 days, except where we are required by law to retain it longer.

We use industry-standard safeguards including encryption in transit (TLS) and at rest, access controls, and regular security reviews. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security.

Depending on your location, you may have the right to:

• Access the personal data we hold about you;
• Correct inaccurate data;
• Request deletion of your data;
• Object to or restrict certain processing;
• Port your data to another service;
• Withdraw consent at any time (without affecting prior processing);
• Lodge a complaint with your local data-protection authority.

To exercise your rights, email privacy@scrappy.app. We respond within 30 days. Scrappy is a trading name of Experiential Intelligence Ltd.

The Service is not directed to children under 13 (or 16 in the EEA). We do not knowingly collect personal information from children. If you believe we have done so in error, please contact us and we will delete the information promptly.

We operate primarily in the European Union. If your data is transferred outside the EEA or UK, we ensure adequate protection through Standard Contractual Clauses or equivalent mechanisms approved by the relevant authorities.

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on the Service at least 14 days before taking effect. Continued use after the effective date constitutes acceptance.

Scrappy
Data Controller
info@ei-digital.com