Last Updated August 7, 2026

This Privacy Policy describes how Colony Labs, Inc. and its affiliates (collectively, “Scribe”, “Company”, “we”, “our”, or “us”) collect, use, disclose, store, secure, and process your personal information and other data for our own purposes when you interact with Scribe and our products and services, and governs your access to and use of our products, services and content, including the Scribe website, Scribe’s digital properties and Scribe's software and downloadable applications (together, the “Services”). Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use available at https://scribehow.com/legal/terms.

In connection with the provision of specific Services, Scribe may provide additional "just-in-time" disclosures or additional information about our practices with respect to your data. These notices may supplement and/or modify this Privacy Policy, or may provide you with additional choices about how Scribe processes, uses, or discloses your data, including personal information.

This Privacy Policy applies only to information made available: (i) to, in or through the Services (ii) when you create a Scribe account; (iii) interact or communicate with us, including via email, phone, or mail, or using our branded social media pages; (iv) register or take part in our marketing, learning, or training events; or (v) complete a questionnaire, promotional entry, a support ticket, or other information request forms. This Privacy Policy does not apply to (i) information Scribe collects or processes in our capacity as a prospective, active, or former employer (which is covered by our employee and candidate privacy notice(s)); (ii) any third-party products, services, websites or content offered by third parties through integrations with the Scribe Services, which are governed by their own respective privacy policies; and (iii) information that we process on behalf of Scribe customers in connection with enterprise-tier subscriptions to Scribe’s product and service offerings, where Scribe otherwise acts as a data processor or service provider under applicable data protection laws, or where Scribe has entered into a contractual arrangement that supersedes and takes precedence over this Privacy Policy (e.g., the Scribe Enterprise Master Services Agreement and Data Processing Agreement) in which case Scribe’s. processing of information is governed by the relevant customer agreements covering access to and use of those product and service offerings.

BY USING ANY SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND ITS TERMS. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY OR ANY OF ITS TERMS, PLEASE DO NOT USE THE SERVICE.

1. How We Collect Your Information

Information you provide us directly. We collect a variety of information that you provide directly to us, including the information detailed below. Providing your personal information is optional. You are not under a legal duty to provide your personal information, but it may be necessary for certain Services and if you do not provide your personal information, we may not be able to provide you with the requested Services.

• Account Information. When you create your account, you will need to provide us with a username, password, your first and last name, and your email address. This may include additional security credential and authentication information from your employer's identity and access management provider in the event that your organization has performed Single Sign on Integration.
• Contact and Professional Information. When you interact with Scribe, we may collect contact and professional such as your name, address, phone number, email address, company name, job title/level, department, and industry.
• Contract and Payment Information. When you contract with us or otherwise purchase the Services, we may collect contract and payment information such as your signature, credit card and bank account information, VAT numbers and other tax identifiers that you use when you pay or contract for the Services.
• Audio/Visual Information. If you attend in-person or virtual events, or join a telephone or video meeting with us, we may record some or all of that event or meeting (including audio and video content), such as by taking photos, conducting interviews, or recording your participation in an interactive session. We will obtain your consent where required under applicable law.
• Communications Information. When you communicate with Scribe, we may collect communication information, such as your feedback on our Services, interactions with our customer success representatives, queries you raise, and chat, email, or call history with our support and sales teams, including interactions with AI-powered support features. This includes information as to how you contact us, and the channel of communication that you use, as well as any information that you send to us.
• Your Activity Data. When you use the Services, we collect your activity data, like clicks, keystrokes, field inputs, screen content other than content redacted through the redaction settings you or your administrator configure as you perform work in applications that you, your employer, or the system administrator for your account enable through the Services, and your inputs into the Services (e.g., your interaction with the Services or data submitted to the Services through these interactions, including via third-party applications, services, and any other content you choose to upload, integrate or interact with using our Services) and the responses, actions and other output generated by the Services based on your input (“Activity Data”).

Information we automatically collect. When you use or interact with our Services, we may automatically collect certain information, including the information detailed below. Scribe uses common information gathering tools, such as tools for collecting usage data, cookies, web beacons and similar tracking technologies to automatically collect information that may contain personal information from your computer or mobile device as you use our Services.

• Analytics Information. We may directly collect analytics data, or use third-party analytics tools (e.g., Google Analytics, DataDog in connection with the Services, including to help us measure traffic and usage trends. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Services. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
• Usage Information. When you use or interact with the Services, we may collect full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and Services, content you viewed or searched for, page response times, download errors, length of visits to certain pages, searches, interactions with AI-powered features (including session frequency, feature usage, and conversation metadata), actions taken within our Services, and page interaction information (such as scrolling, clicks, and mouse-overs).
• Cookies Information. When you use or interact with the Services, we or third parties may place or send one or more cookies, pixels, and other tracking technologies (“Tracking Technologies”) that uniquely identifies you, your computer or your browser. A cookie is a small text file containing a string of alphanumeric characters that, among other things, helps you log into the Services faster and enhances your navigation and use of the Services. For more information please see the “Cookies and Other Tracking Technologies” Section of this Privacy Policy below.
• Log and Device Information. Log information is automatically reported by your browser or mobile device each time you access or use the Services. When you use our Services, our servers automatically record certain log file information. These logs may include your web request, Internet Protocol (“IP”) address, device, application, or browser type and version, browser plug-in type and version, operating system, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, occurrences of technical errors, diagnostic reports, your settings preferences, API calls.
• Authentication Information. When you use our Services as a member of an organization that has performed Single Sign On integration, we collect information from the identity and access management provider related to your role, contact information, and name.

Information we collect from other sources. Depending on your specific use of the Services or interactions with Scribe, we may collect certain information from other sources and combine it with information otherwise provided above, as detailed below.

• Your employer and its representatives. We may receive information about you, such as your title, level, team, applications used with the Services and other information, from your employer and their service providers or authorized representatives (including employer admins of Scribe accounts) in connection with your and their use of the Services.
• Other Scribe users. We may receive information about you, such as contact and professional information, from other users, such as our customers and their current or prospective administrators of Scribe accounts or partners that refer you to Scribe via our referral programs.
• Public and third-party sources for sales and marketing. To the extent permitted by applicable laws, we collect information about prospective and existing users of our Services from publicly- and commercially-available sources and services. This information may include information such as your social profile (e.g. LinkedIn), name, email address, physical address, phone number, and professional information.

2. How We Use Your Information and the Legal Bases for Processing Your Information

How Scribe uses your information, and our legal bases for using your personal information, depends on a combination of how you interact with Scribe and interact with and use the Services, the choices you make with respect to such interaction and/or use that you have communicated to us, and your location, but includes the uses and their respective legal bases below. In jurisdictions where applicable law distinguishes between primary processing purposes and ancillary processing purposes, our sales, advertising and marketing is considered an ancillary purpose, while all other processing purposes described in this Section are primary purposes.

Scribe may use your information or information about you to:

• Create, register, maintain and administer your Scribe account and subscription to the Services, including through use of your account information, authentication information, contact and professional information, contract and payment information, communications information, usage information, analytics information, log and device information, and cookies information as described in our Cookie Notice.
  • Legal Basis(es): Contractual necessity (e.g., Article 6(1)(b) GDPR) and/or Legitimate interests (e.g., Article 6(1)(f) GDPR)
• Operate, provide, deliver and perform the Services, including through use of your account information, authentication information, audio/visual information, contact and professional information, contract and payment information, communications information, usage information, analytics information, log and device information, Activity Data, and cookies information as described in our Cookie Notice.
  • Legal Basis(es): Contractual necessity (e.g., Article 6(1)(b) GDPR) and/or Legitimate interests (e.g., Article 6(1)(f) GDPR)
• Communicate with you (e.g., in-person, through email, by phone, through video, in live and/or AI-assisted chat), respond to your requests for information, inquiries and complaints, and provide notices, including through use if your account information contact and professional information, communications information, and audio and video information.
  • Legal Basis(es): Legitimate interests (e.g., Article 6(1)(f) GDPR) and/or Contractual necessity (e.g., Article 6(1)(b) GDPR)
• Conduct sales, marketing and promotional activities or otherwise contact you regarding our products, services, and other information that we think may be of interest to you, including through use of your account information, contact and professional information, contract and payment information, communications information, usage and interaction information, log and device information, Activity Data and cookies information as described in our Cookie Notice.
  • Legal Basis(es): Legitimate interests (e.g., Article 6(1)(f) GDPR), Consent (where legally required) (e.g., Article 6(1)(a) GDPR)
• Customize and personalize the Services and its content, and make recommendations to you, including through use of your account information, contact and professional information, contract and payment information, communications information, usage information, log and device information, Activity Data and cookies information as described in our Cookie Notice.
  • Legal Basis(es): Contractual necessity (e.g., Article 6(1)(b) GDPR), Legitimate interests (e.g., Article 6(1)(f) GDPR) and/or Contractual necessity (e.g., Article 6(1)(b) GDPR)
• Develop, improve, benchmark and report on the Services, their features and functionality, and other products and services we may offer (including developing, training and fine-tuning Scribe’s machine learning and artificial intelligence models) including through use of your Activity Data, analytics information, usage information, and log and device information, except to the extent you have enabled any applicable opt-out or configured applicable exclusions made available by Scribe in or through the Services.
  • Legal Basis(es): Consent (where legally required) (e.g., Article 6(1)(a) GDPR) and Legitimate interests (Article 6(1)(f) GDPR)
• Engage in analysis, marketing research, and reports regarding use of our Services, including through use of your Activity Data, analytics information, usage information, log and device information and contact and professional information
  • Legal Basis(es): Consent (where legally required) (e.g., Article 6(1)(a) GDPR) and Legitimate interests (Article 6(1)(f) GDPR)
• Comply with, and enforce our rights under, any applicable laws, including but not limited to our obligations to respond to your requests under applicable data protection laws, including through use of your account information, contact and professional information, contract and payment information, communications information, usage and interaction information, log and device information, Activity Data, authentication information and other information as may be required to protect our business interests and comply with applicable laws
  • Legal Basis(es): Contractual necessity (e.g., Article 6(1)(b) GDPR), Compliance with a legal obligation (e.g., Article 6(1)(c) GDPR) and/or Legitimate interests (e.g., Article 6(1)(f) GDPR)
• Detect, prevent, and respond to potential or actual security incidents, and to monitor and protect against other malicious, deceptive, fraudulent, illegal or inappropriate activity, including through use of your account information, contact and professional information, audio and visual information, contract and payment information, communications information, usage and interaction information, log and device information, Activity Data, and authentication information.
  • Legal Basis(es): Legitimate interests (e.g., Article 6(1)(f) GDPR), Compliance with a legal obligation (e.g., Article 6(1)(c) GDPR)
• Enforce legal agreements, including our Terms of Use and this Privacy Policy, and protect our legitimate business interests and legal rights, including through use of your account information, contact and professional information, contract and payment information, communications information, usage and interaction information, log and device information, Activity Data, authentication information, and other information as may be required to protect our business interests and enforce our rights.
  • Legal Basis(es): Legitimate interests (e.g., Article 6(1)(f) GDPR), Compliance with a legal obligation (e.g., Article 6(1)(c) GDPR)
• We may use the information we collect or receive to communicate directly and indirectly with you. We may send you emails containing newsletters, promotions and special offers related to the Service. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences.
  • Legal Basis(es): Legitimate interests (e.g., Article 6(1)(f) GDPR), Consent (where legally required) (e.g., Article 6(1)(a) GDPR)
• With your consent. We use information about you where you have given us consent to do so for a specific purpose not listed above.

Scribe may also aggregate and/or de-identify information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). Scribe may use Aggregate/De-identified Information for any lawful purpose. To the extent that we process Aggregate/De-Identified Information, we will maintain and use it in aggregated and/or de-identified form and not attempt to re-identify the information, except as permitted by law. The legal basis for aggregating or de-identifying data to create or use Aggregate/De-Identified Information is Legitimate interests (e.g., Article 6(1)(f) GDPR).

Notwithstanding the above, we do not use any data obtained through your organization's identity and access management providers, including data required to manage digital identities and control user access to networks, applications, and data ("IDP Data") for developing, improving, or training any artificial intelligence or machine learning algorithms. Specifically, Scribe only accesses and processes IDP Data as necessary to perform identity and access management functions, including authentication, multi-factor authentication, authorization, and secure sign-on, in strict compliance with applicable IDP API policies and with your instructions.

3. Cookies and Other Tracking Technologies

We and third parties acting on our behalf use Tracking Technologies to collect certain information about your interactions with the Services. Most browsers accept Tracking Technologies automatically, but you may be able to control the way in which your devices permit the use of certain Tracking Technologies. If you so choose, you may block or delete certain Tracking Technologies from your browser. However, blocking or deleting cookies may cause some of the Services, including login features and general functionality, to work incorrectly or not at all. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

Your browser settings may allow you to transmit a “Do Not Track” signal, “opt-out preference” signal or other mechanism for exercising your choice regarding the use and disclosure of your personal information when you visit various websites. Our Services recognize the Global Privacy Control (GPC) signal, which enables you to opt-out of certain uses or disclosures of your information. We will treat our initial receipt of the GPC signal as a valid request to opt-out of the processing of your personal information for targeted advertising. Please note that if you are not logged into your account, our processing of the signal will be limited to the browser that you are using. You may need to renew your opt-out choice if you use a different browser to access our Service. If there is a conflict between the GPC signal and a manual choice you have made on our site regarding targeted advertising, we will honor your manual choice. Other than GPC, we do not recognize any “Do Not Track” signals.

You may also opt-out of the collection and use of information for interest-based advertising by advertisers that are part of certain industry alliances, including through tools offered by the National Advertising Initiative, the Digital Advertising Alliance or the European Interactive Digital Advertising Alliance, by clicking the links provided.

Please review the Scribe Cookie Policy at https://scribehow.com/legal/cookies for additional details about our use of Tracking Technologies and how to manage them.

4. How We Disclose Your Information

We may disclose your information or information about you in the following ways.

• Service Providers. We may share your information with Scribe service providers, subprocessors, contractors and other third party service providers (like professional advisors who provide consultancy, banking, legal, insurance and accounting services), as needed to help us operate our business, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing, or where we otherwise have a legitimate business interest to do so. These third party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Service providers who are classified as sub-processors are held to standards of data protection no less rigorous than applicable data protection laws require.
• Third Party Products, Services and Providers. We make available to you services, software, and content provided by third parties for use with, on or through our Services (e.g., requested integration with third-party applications). We disclose information related to those transactions to such applicable third party(ies).
• Organization Administrators. If you create an account using an email address belonging to your employer or any other organization, we may share the fact that you have a Scribe account and certain of your account information, contract and payment information, log and device information, authentication information and contact and professional information with your employer and any other administrator of your or your employer’s account, including but not limited to your name, email address, last login, and means of authentication (e.g., SSO) for example, to ensure that you are added to their business account or the Services are configured to meet your organization’s requirements.
• Protection of Scribe and Others. We will disclose your information where it is appropriate or otherwise required to (i) comply with by law or compulsory legal process; (ii) enforce our terms or agreements (including This Privacy Policy and our Terms of Use), protect the rights, property, or safety of Scribe, the Services, or our employees, customers, users, and others ; and/or (c) respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
• Business Transfers. We may share your information in connection with or anticipation of a business transaction, such as if we buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. This may include assets such as databases. In the event of a transfer of personal information due to the completion of a business transaction that results in a change of controller, data subjects would be notified promptly and without undue delay of that change.
• Third-Party Marketing. We provide information (such as your internet or other similar network activity, identifiers such as your name and email address, location information, and inferences about your interests) to third parties, including advertising networks that allows them to serve you with more useful and relevant Scribe sales and marketing materials, and to measure their effectiveness. For more information about your choices relating to our advertising, see the “Your Data Subject Rights” Section below.
• Aggregate/De-Identified Information. We may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. This Policy places no restrictions and no limitations on our use or sharing of Aggregate/De-Identified Information for any lawful purpose.
• Sharing and Sale of Personal Information. We may license or otherwise disclose any of the information made available to the Services, including your personal information to third parties for their own business purposes, which may include for developing and improving their own services and developing, training, and/or fine-tuning artificial intelligence and machine learning models. This may be considered a “sale” or “sharing” of personal information under certain data protection and privacy laws. However, we will not nor do we have actual knowledge that we have sold or shared the personal information of individuals under 16 years of age. If you would like to opt-out of future “sales” and/or “sharing” please see the Section entitled “Your Data Subject Rights”.
• Affiliates. We may disclose your personal information or any other information about you to our affiliates within the Scribe corporate group as well as companies we may acquire in the future when they become part of our corporate group.
• Consent. We may also disclose your information to third parties with your consent or authorization.

For further information on the recipients of your personal information, please contact us at the address stated under the "How to Contact Us" Section below.

5. How We Transfer, Store, Retain And Secure Your Information

Retention, storage and use of your information. Scribe retains your personal data and other information about you and that you make available to us for as long as reasonably necessary for the purposes and criteria outlined in this Privacy Policy and explained further in the Scribe Trust Center at https://trust.scribehow.com.

When personal data and other information collected is no longer required by us, we and our service providers will perform the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form as permitted or required under applicable laws. If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to other users or materials you generated through your use of Services to other members of your organization or users of your account.

Cross-Border transfer of your information. By using the Services, you acknowledge and agree that your information may be transferred to, used, processed, or held by us in the United States and in other countries, including countries outside of your country of residence and used for the purposes set out in this Privacy Policy. Where Scribe transfers information outside the territory in which it was made available to us (e.g., the EEA or the UK), we ensure it benefits from an adequate level of data protection by relying on either adequacy decisions (such as the countries with EU adequacy decisions listed here and countries with UK adequacy decisions listed here), standard contractual clauses (such as to affiliates and third parties in countries without an adequacy decision, like the United States), or where required or permitted by applicable law, we may rely on other appropriate safeguards, including derogations for specific situations (such as your explicit consent or the performance of a contract with you), or other legally recognized transfer mechanisms (e.g., the EU-U.S. Data Privacy Framework).

For further information on the legal transfer mechanisms we use, please contact us as detailed in the “How to Contact Us” Section below.

Securing your information. Scribe implements appropriate industry standard technical and organizational measures designed to secure information and protect it from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For more information on where and how we store your information, please visit the Scribe Trust Center at https://trust.scribehow.com.

Although Scribe implements and maintains safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet and the unpredictable actions of bad actors and foreign states, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

6. Children’s Privacy

The Services are not provided to nor intended for use by children. Scribe does not knowingly collect personal information or other data from children under the age of 16 (or such other age of minority under applicable law for heightened privacy obligations, such as 13 in the United States) without the consent of the child’s parent or guardian. In the event that we learn that we have collected personal information from a child without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child, please contact us at [email protected].

7. Links To Other Web Sites And Services

The Services may contain links to third-party websites and services. We are not responsible for the practices employed by these websites or services, including the information or content contained therein. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function.

Because these third-party websites and services are not operated by us, we are not responsible for the content or practices of those websites or services. Please remember that when you use a link to go from the Services to another website, our Privacy Policy does not apply to those websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.

8. Your Data Subject Rights

Depending on your location, you may have certain rights in relation to your personal information. However, please note that a number of these rights only apply in certain circumstances, and each of such rights may be limited by law. To exercise any such applicable rights, please contact us as described under the “How to Contact Us” Section below, or as otherwise described in this Privacy Policy.

Subject to applicable law, such rights may include, without limitation, the following:

• Request access to the personal information we process about you. You may be entitled to request access to the information we have processed about you and to obtain the details about what personal information we have collected about you, including the categories of information, the categories of sources from which the information was collected, the business or commercial purposes for collecting, selling or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• Request the correction/rectification of your personal information. You may be entitled to request rectification of data about you that is inaccurate or incomplete.
• Request the erasure of your personal information. You may be entitled to request deletion of your personal information.
• Request the restriction of the processing of your personal information. You may be entitled to request that Scribe restrict processing activities of your personal information.
• Request portability of your personal information. You may be entitled to request a copy of your personal information (in a structured, commonly used and machine-readable format) to transfer this data to another data controller.
• Object to certain processing of your personal information. You may be entitled to request that Scribe no longer process certain of your personal information.
• Request notification of third parties. You may be entitled to request that we inform any third parties to whom we’ve disclosed your personal information of your correction, deletion, or restriction requests.
• Request to withdraw your consent. You may be entitled to, if we have collected and processed your personal information with your consent, withdraw your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal of consent, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Opt-out of the “sale” or the “sharing” or processing of your personal information. You may be entitled to request to opt-out of the “sale” of your personal information or the “sharing” of your personal information, as well as the processing of your personal information for targeted advertising (as those terms are defined under applicable law). To exercise this right, please contact Scribe’s Privacy Team at [email protected] or refer to the Scribe Trust Center at https://trust.scribehow.com for details on configuring applicable Services to opt-out of such “sale”, “sharing”, and/or processing.

Please note that under many countries' laws, you have the right to lodge a complaint with the supervisory authority in the place in which you live or work. A full list of EU supervisory authorities’ contact details is available here. If you live or work in the UK, you have the right to lodge a complaint with the UK Information Commissioner’s Office. If you live in Brazil, you have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD). If you live in Australia, you have the right to lodge a complaint with the Office of the Australian Information Commissioner. If you live in South Africa, you have the right to lodge a complaint with the Information Regulator of South Africa.

We will not retaliate or discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before exercising these rights, such as your email address or government issued ID. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. If we deny your request, you may appeal our decision by contacting us through the methods described in the “How to Contact Us” Section below,.

9. How To Contact Us

Please contact us at [email protected] if you have any questions, concerns, or complaints regarding this this Privacy Policy or information we may have collected about you, and to request to access, review, revise, or delete such information.

If you live in the European Economic Area (EEA), UK or Switzerland, please contact [email protected] if you have any questions pertaining to GDPR and your rights thereunder.

Our EU Representative:

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent.

Our nominated EU Representative is :

Instant EU GDPR Representative Ltd.

Adam Brogden

[email protected] Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD

Office 2, 12A Lower Main Street, Lucan Co. Dublin K78 X5P8, Ireland

Our UK Representative:

Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is:

GDPR Local Ltd.

Adam Brogden

[email protected] Tel +44 1772 217800

1st Floor Front Suite

27-29 North Street, Brighton England BN1 1EB

10. Changes To Our Privacy Policy

Scribe regularly offers new products, services, and functionality across the Scribe platform and reserves the right to update or modify this Privacy Policy at any time with immediate effect, subject to any applicable legally-required notice to you. Because we may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, you should review this page periodically. We keep our Privacy Policy under review to ensure it is current, compliant, and accurate. When we make a material change to this policy, we will update the ‘last modified’ date at the top of this page, and may also provide additional materials regarding such change (e.g., summary of changes) in the Scribe Trust Center at https://trust.scribehow.com.

11. California Residents

This Section applies to you if you are a resident of California and we process personal information about you that is subject to the California Consumer Privacy Act and the California Privacy Rights Act (together, the "CCPA"). For purposes of this Section, references to “personal information” shall include “sensitive personal information” as defined under the CCPA.

In the preceding 12 months, we collected and disclosed to service providers (as described in the “How We Disclose Your Personal Information” Section above) the following categories of personal information and sensitive personal information (denoted by *):

• Identifiers, such as name, e-mail address, IP address
• Personal information categories listed in the California Customer Records statute such as name, address, or telephone number
• Commercial information such as records of products or services purchased
• Biometric information* such as voice recordings
• Internet or other similar network activity such as information regarding your interaction with the Services
• Geolocation data such as IP address
• Audio, electronic, visual, thermal, olfactory, or similar information such as photographs, video recordings and voice recordings
• Professional or employment-related information such as title of profession, employer, professional background
• Inferences drawn from other personal information such as your preferences, interests and other information used to personalize your experience
• Account access credentials* such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account
• Precise geolocation data*
• To the extent not redacted through your configuration and use of redaction capabilities in the Services and/or to the extent made available by you or your organization as Activity Data, Government identifiers* such as driver’s license or passport number; the contents of an individual’s mail, email, and text messages*; and personal information concerning an individual’s health* such as information submitted in relation to a request for workplace accommodations.

The categories of sources from which we collect your personal information and the specific purposes for which we collect and disclose your personal information, are described in the Sections above, How We Collect Your Information, How We Use of Your Information and the Legal Bases for Processing Your Information, and How We Disclose Your Information, respectively. We only use and disclose sensitive personal information for purposes specified in the CCPA or otherwise in accordance with your consent.

Categories of personal information “sold” and “shared.” As discussed above and detailed in the Scribe Cookie Policy at https://scribehow.com/legal/cookies, we use cookies and similar technologies to understand how well our online advertising works, and deliver more targeted online advertising and marketing campaigns. Over the past twelve months, we may have disclosed your internet or other similar network activity, identifiers and location information, and inferences about your interests to third parties, including, advertising networks, data analytics providers, social networks and advertising partners. The CCPA may consider our disclosures of this information to third parties as “sales” or “sharing” of personal information. Scribe does not have actual knowledge that it “sells” or “shares” the personal information of individuals under 16 years of age.

California Shine the Light: California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their ‘personal information’ (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to [email protected].

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