Privacy Policy
Last updated: 5 March 2026
1. Introduction
Scouter Systems, a trading name of Considered Businesses LTD ("we", "us", or "our"), is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, and share data when you use our software-as-a-service platform (the "Service").
2. Legal Framework
This policy is issued in compliance with:
- The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018
- The EU General Data Protection Regulation (EU GDPR) 2016/679, as applicable to data subjects in the European Economic Area
- The Privacy and Electronic Communications Regulations 2003 (PECR)
- The California Consumer Privacy Act (CCPA), as amended by the CPRA, for California residents
3. Telemetry Data (Data Collected via the Service)
Scouter Systems collects website analytics data on behalf of our customers. This telemetry data includes page views, URLs visited, device and browser information, and custom events defined by the customer.
This data is anonymous. We do not collect IP addresses, use cookies, or employ any persistent identifiers. The telemetry data cannot be used to identify individual website visitors and does not constitute personal data under the UK GDPR or EU GDPR.
4. Customer Account Data
We collect the following personal data from our customers (the businesses that use Scouter Systems):
| Category | Data Elements | Purpose | |----------|--------------|---------| | Account Information | Email address | Account creation, authentication, and communication | | Billing Information | Billing address, invoice history, last four digits of payment card (full card details are handled exclusively by Stripe and never touch our systems) | Payment processing and invoicing |
5. Lawful Basis for Processing
We process customer personal data on the following legal bases under Article 6(1) of the UK GDPR and EU GDPR:
- Contract: Processing necessary for the performance of our contract with you to provide the Service (Article 6(1)(b))
- Legitimate interests: Processing necessary for our legitimate business interests, such as improving our Service and ensuring security (Article 6(1)(f))
- Legal obligation: Processing necessary to comply with applicable laws or regulations (Article 6(1)(c))
6. Sub-Processors
We use third-party sub-processors to help deliver the Service. The following is a representative, non-exhaustive list:
| Provider | Purpose | |----------|---------| | Hetzner Online GmbH | Infrastructure and hosting | | Cloudflare, Inc. | Backup infrastructure (EU jurisdiction) | | Stripe, Inc. | Payment processing | | Postmark (ActiveCampaign, LLC) | Transactional email |
7. Data Retention
- Account data: Deleted immediately upon account deletion
- Billing data: Retained for 7 years to comply with UK tax and accounting obligations (Companies Act 2006, HMRC requirements)
- Telemetry data: As this data is anonymous, GDPR retention requirements do not apply
8. Your Rights
Under the UK GDPR and EU GDPR, you have the following rights in relation to your personal data:
- Right of access: Obtain confirmation of processing and a copy of your data (Article 15)
- Right to rectification: Request correction of inaccurate or incomplete data (Article 16)
- Right to erasure: Request deletion of your data in certain circumstances (Article 17)
- Right to restriction: Request restriction of processing in certain circumstances (Article 18)
- Right to data portability: Receive your data in a structured, machine-readable format (Article 20)
- Right to object: Object to processing based on legitimate interests or for direct marketing (Article 21)
These rights apply to your customer account data. Because telemetry data is anonymous and cannot identify individuals, data subject rights do not apply to it.
To exercise any of these rights, please contact us at support@scouter.systems. We will respond within one month of receiving your request, as required by law.
If you are a California resident, you also have the right to know what personal information is collected, the right to delete, the right to opt out of the sale of personal information, and the right to non-discrimination under the CCPA/CPRA.
9. International Data Transfers
Your personal data is primarily stored and processed within the European Economic Area (EEA) on Hetzner infrastructure in Germany, with backup infrastructure on Cloudflare's EU jurisdiction. Where we use sub-processors located outside the EEA or the UK, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) or adequacy decisions.
10. Data Security
We implement appropriate technical and organisational measures to protect your data, including access controls, firewall rules, and automated backups.
11. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours and, where required, affected data subjects without undue delay, in accordance with Articles 33 and 34 of the UK GDPR.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on our website.
13. Contact Us
If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact:
Scouter Systems, a trading name of Considered Businesses LTD (company number 15746962) Email: support@scouter.systems Address: 94a Dickson Road, Blackpool, England, FY1 2BU
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe your data protection rights have been infringed. If you are based in the EEA, you may also contact your local supervisory authority.