Effective date: 14 July 2021
We respect your right to privacy and make sure that your personal data is collected and used in compliance with the highest data protection standards.
- General information
- Types and purposes of personal data
- Non-personal data
- Commercial communication
- How long do we keep your data?
- How do we share and disclose data?
- International transfers of personal data
- Protection of personal data
- Your rights regarding personal data
- Term, termination and amendments
- Contact us
1. General information
1.2 Data controller
Scrupulosity.com is owned and operated by Scrupulosity Solutions, LLC (“we”, “us”, or “our”), having the business address listed at the bottom of this policy, who is also responsible for the processing of your personal data. We act as a data controller with regard to your personal data collected through Scrupulosity.com.
1.3 What is Scrupulosity.com?
Scrupulosity.com is a spiritual coaching service that provides information about powerful biblical secrets for escaping the obsessive-compulsive cycle, allows ordering scrupulosity recovering courses (the “Courses”) and booking coaching sessions (the “Coaching Sessions”).
Scrupulosity.com should not be accessed and used by persons under the age of 18. Therefore, we do not knowingly collect personal data of persons under the age of 18.
2. Types and purposes of personal data
We collect only a minimal amount of personal data that is necessary for ensuring your proper use of Scrupulosity.com. We use your personal data for specified and limited purposes. In this section, we explain what personal data we collect from you, for what purposes we use that data, and on what legal bases we rely when processing your personal data.
2.1 Types of personal data
We comply with data minimisation principles. Thus, we collect only a minimal amount of personal data that is necessary for your use of Scrupulosity.com. The list of the types of personal data that we collect from you is provided in section 2.3 below.
2.2 Purposes of personal data
2.3 Overview of types and purposes of your personal data
The list below provides a detailed description of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing your personal data.
- When you subscribe to our newsletter, we collect your email address. We use your email address to provide you with access to our free video training and deliver you our newsletter. The legal basis that we rely upon is ‘your consent’.
- When you leave a reply under our blog posts, we collect your name, email address, website, and any information that you decide to provide us in your comment. We use such personal data to feature your comment, prevent abuse and scam, analyse our business and contact you (if necessary). The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and improve our business and prevent abuse) and ‘your consent’.
- When you complete a quiz, we collect your email address. We use your email address to send you your quiz results, provide you with access to our free video training, and deliver you our newsletter. Please note that we may match your email address with your quiz results in order to deliver you relevant advertising (see section 4.5 for more information). The legal bases that we rely upon are ‘your consent’ and ‘pursuing our legitimate business interests’ (i.e., to promote our business).
- When you order the Coaching Session, we collect your name, email address, phone number, and payment information (name on your card, card number, and expiration date). We use such data to schedule your appointment, process your payment, send you a reminder, provide you with the requested services, contact you (if necessary), and keep our business records. The legal bases on which we rely are ‘performing a contract with you’, ‘pursuing our legitimate business interests’ (i.e., to administer our business) and ‘your consent’ (for optional personal data).
- When you subscribe to our Scrupulosity Academy, we collect your email address and payment information (card number). We use such data to process your payment, provide you with the requested services, contact you (if necessary), and keep our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate business interests’ (i.e., to administer our business).
- When you apply for a recovery program, we collect your name, email address, phone number, age, and other scrupulosity-related information that you decide to provide. We use such data to enrol you to the program, contact you (if necessary), and keep our business records. The legal bases on which we rely are ‘performing a contract with you’, ‘pursuing our legitimate business interests’ (i.e., to administer our business) and ‘your consent’ (for optional personal data).
- When you contact us by email, we collect your name, email address, and any information that you decide to provide in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data).
- When you contact us through Facebook chat available on Scrupulosity.com, we may see your Facebook account data like your name and profile photo. When chatting with us, you may also provide us with other information about yourself that you deem to be necessary. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data).
2.4 Sensitive data
When you use Scrupulosity.com, we may collect special categories of personal data (“sensitive data”) from you. For example, you may decide to share with us your health-related information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation. You do not have to provide the said sensitive data if you do not wish to do so – the provision of such sensitive data is optional and you may choose what sensitive data you would like to share during your sessions. Your sensitive data will be kept in strict confidentiality and used only for the sole purpose of providing you with the requested services. The legal bases on which we rely are ‘your consent’ and ‘performing a contract with you’.
2.5 Failure to provide personal data
If you decide not to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to use the full functionality of Scrupulosity.com, receive the services provided through Scrupulosity.com, or get our response. Please contact us if you think that any personal data that we collect is excessive.
2.6 Confidentiality of communication
When you participate in our Coaching Sessions, you communicate directly with us. We put reasonable efforts to ensure that any communication data transmitted through Scrupulosity.com remains confidential and properly protected. Moreover, we do not intentionally and directly access, manage, correct, delete, share, or disclose any information that you communicate to us during the Coaching Sessions.
3. Non-personal data
When you use Scrupulosity.com, we collect some technical data about your device and visits. In this section, we inform you what non-personal data we collect from you and for what purposes we use that data.
3.1 What non-personal data do we collect?
In order to analyse Scrupulosity.com, we use website analytics service Plausible (https://plausible.io) that automatically collects certain technical non-personal data about your use of Scrupulosity.com. Such non-personal data does not allow us us to identify you. The non-personal data collected Plausible includes the following information:
- The operating system that you use;
- The device type that you use;
- The browser that you use;
- URL address clicked from com; and
- Your country.
3.2 Your feedback
If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response, if any. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).
3.3 How do we use non-personal data?
We will use non-personal data for the following purposes:
- To analyse what kind of users visit and use Scrupulosity.com;
- To examine the relevance, popularity, and engagement rate of the content available on Scrupulosity.com;
- To investigate and help prevent security issues and abuse;
- To develop and provide additional features to Scrupulosity.com; and
- To personalise Scrupulosity.com for your specific needs.
3.4 Aggregated and de-identified data
In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.
4. Commercial communication
From time to time, you may receive promotional messages from us. In this section, we explain when you may receive notices from us and what you can do to decline our commercial communication.
4.1 Marketing messages
To keep you updated about the latest developments related to Scrupulosity.com, our new services, additional features of Scrupulosity.com, and special offers, we may send you our newsletters. Our newsletters will be sent only if:
- We receive your express (“opt-in”) consent to receive marketing messages (please note that your voluntary subscription for our newsletters substitutes such consent); or
- We decide to send you marketing messages about our new services that are closely related to the services already used by you.
You can opt-out from receiving marketing messages at any time free of charge by clicking on the “unsubscribe” link contained in any of the newsletters sent to you or by contacting us directly.
4.3 Informational notices and service updates
From time to time, we may send you important informational notices, such as service-related, technical or administrative emails, information about your bookings and payments, your privacy and security, and other administrative matters. Please note that we will send such notices on an “if-needed” basis and they do not fall within the scope of direct marketing communication that requires your prior consent.
4.4 Personalised advertising
After visiting Scrupulosity.com, you may encounter targeted interest-based ads that are generated on the basis of your use of Scrupulosity.com. You can control how such advertisements are shown to you or opt-out from targeted advertising by consulting the guide powered by the Digital Advertising Alliance available at https://youradchoices.com. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org
4.5 Facebook Lookalike and Custom Audiences
If you submit us your email address for marketing purposes, we may use it for generating Facebook Lookalike Audiences offered by Facebook, Inc. Facebook Lookalike Audiences is an advertising and behavioural targeting service that allows us to reach people who may be interested in scrupulosity.com and show targeted advertising to potential customers that share similar interests and demographics as our current customers. To ensure privacy, Facebook irreversibly hashes (encrypts) email addresses and do not use them for other purposes (see https://www.facebook.com/business/help/112061095610075/ for more information). We do not have access to the personal data of persons belonging to the members of Facebook Lookalike Audience, unless they decide to click on our ad. You can opt out from ad personalisation by visiting https://optout.aboutads.info/?c=2&lang=EN or adjusting your Google settings (see https://adssettings.google.com/authenticated). Before obtaining your email address for Facebook Custom Audiences, we will inform you about our use of automated marketing strategies and, if necessary, we will obtain your consent for such purposes. Your consent can be revoked at any time.
5. How long do we keep your data?
We store your personal data only if it is necessary for its specific and limited purposes. In this section, we specify the time period for which we keep your personal and non-personal data in our systems.
5.1 Retention of personal data
5.2 Retention of non-personal data
5.3 Retention as required by law
Please note that, in some cases, we may be obliged by law to store your personal data for certain period of time (e.g., for accountancy purposes). In such cases, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
6. How do we share and disclose data?
We may need to cooperate with external service providers and share some personal data with them. In this section, you can find information about third parties that have access to your personal data and the instances when we make data transfers.
6.1 Do we disclose your personal data?
If necessary, we will disclose your personal data to the service providers with whom we cooperate (our data processors). For example, we may share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties.
6.2 When do we disclose your personal data?
The disclosure of your personal data is limited to the situations when such data is required for the following purposes:
- Ensuring the proper operation of Scrupulosity.com;
- Ensuring the delivery of the services requested by you;
- Providing you with the requested information;
- Pursuing our legitimate business interests;
- Enforcing our rights, preventing fraud, and security purposes;
- Carrying out our contractual obligations;
- Law enforcement purposes; or
- If you provide your prior consent to such a disclosure.
6.3 With what data processors do we share your personal data?
- Our hosting and cloud storage service provider SiteGround (https://www.siteground.com) located in Bulgaria;
- Our marketing service provider Kajabi (https://kajabi.com) located in the US;
- Our email marketing service provider Mailerlite (https://www.mailerlite.com) located in Lithuania;
- Our payment service providers Stripe (https://stripe.com) located in the US;
- Our live chat and marketing service provider Facebook (https://www.facebook.com) located in the United States;
- Our appointment scheduling service provider Calendly (https://calendly.com) located in the United States;
- Our video communication software provider Zoom (https://zoom.us) located in the US;
- Our analytics service provider Google Analytics (https://analytics.google.com) located in the United States; and
- Our video platform provider YouTube (https://www.youtube.com) located in the United States.
- Our online community platform provider Circle (https://circle.so) located in the United States.
- Our subscription management platform provider SureCart (https://surecart.com) located in the United States.
- Our automation engine platform provider SureTriggers (https://suretriggers.com) located in the United States.
6.4 Sharing of non-personal data
Your non-personal data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving Scrupulosity.com, responding to lawful requests from public authorities or developing new products and services.
6.5 Legal requests
If requested by a public authority, we will disclose information about the users of Scrupulosity.com to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
7. International transfers of personal data
Your personal data may be transferred outside the country where you reside. In this section, we explain when we transfer personal data abroad and what safeguards we implement to ensure that your personal is properly protected.
8. Protection of personal data
We put our best efforts to keep your personal data safe and secure. In this section, we inform you about our technical measures that help us to protect your personal data.
8.1 Our security measures
We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include secured networks, SSL protocol, strong passwords, limited access to your personal data by our staff, and anonymisation of personal data (when possible). In order to ensure the security of your personal data, we kindly ask you to use Scrupulosity.com through a secure network only.
8.2 Handling security breaches
Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
9. Your rights regarding personal data
You have the right to control how we process your personal data. Below, we list the rights that you can exercise with regard to your personal data and explain how you can exercise those rights.
9.1 What rights do you have?
Subject to any exemptions provided by law, you may ask us to:
- Get a copy of your personal data that we store;
- Get a list of purposes for which your personal data is processed;
- Rectify inaccurate personal data;
- Move your personal data to another processor;
- Delete your personal data from our systems;
- Object and restrict processing of your personal data;
- Withdraw your consent, if you have provided one; or
- Process your complaint regarding your personal data.
9.2 How to exercise your rights?
If you would like to exercise any of your rights listed in section 9.1, please contact us by email at email@example.com and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable time frame but no later than 2 weeks.
9.3 How to launch a complaint?
If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
10. Term, termination and amendments
10.1 Term and termination
11. Contact us
You can contact us at any time to receive further clarifications. Our contact details are specified below.
Contact form: https://scrupulosity.com/contact/
Postal address for communication: Scrupulosity Solutions, LLC, 3755 Sharp Rd, Glenwood, MD 21738, the United States of America