Thank you for visiting our Website and\/or using our Services.<\/p>\n
We respect your privacy. When it comes to your personal information, we believe in transparency, not surprises. We want you to know what personal data we collect, what we do with it as well as your choices and rights at law.<\/p>\n
Although our goal is to always be as clear and transparent as possible, we appreciate that legal documents can sometimes be difficult to read. However, we strongly encourage you to read this Privacy Policy with care. Please do not hold back from contacting us for any clarification you may need with respect to the processing of your personal data by us.<\/p>\n
This Privacy Policy shall be without prejudice to any confidentiality obligations subsisting under relevant contractual arrangements and any liability associated therewith or arising therefrom.<\/p>\n
We may need to revise and update this Privacy Policy from time to time to make sure we provide you, at all times, with the information you are entitled to receive under applicable law, as well as for us to ensure that our Privacy Policy addresses your data protection concerns, and that we are\/remain compliant with applicable law.<\/p>\n
Key Terms<\/u><\/em><\/p>\n When we say \u2018us\u2019, \u2018we\u2019 or \u2018our\u2019, we mean Scope (\u2018Scope\u2019), a commercial partnership duly constituted under the Laws of Malta and registered with the Malta Business Registry, with its registered and business address at Scope, Digital Hub, Malta Life Sciences Park, San Gwann, SGN 3000, Malta. Scope enjoys authorised partner\/reseller status with a number of independent software vendors of cloud-based software applications. We therefore provide our clients with a comprehensive business solution which comprises procuring or facilitating access to\/use of subscription-based cloud-based applications or what is commonly referred to in the industry as Software as a Service (\u2018SaaS\u2019), as well as the provision of value-added services including software customization, implementation, data migration, maintenance and support services, in our quality as a partner\/reseller of the relevant SaaS solutions;<\/p>\n When we refer to \u2018you\u2019 or \u2018your\u2019, we mean the Client, any Account User or connected organisation, as well as our officers, employees, business partners and suppliers, as the case may be, and any Data Subjects whose personal data is being processed by us, including Website Users and anyone attending our events;<\/p>\n When we refer to \u2018Account User\u2019, we mean the Client and any other person or entity, including connected organisations, who is permitted access to\/use of the relevant SaaS applications made available and\/or supported by us or who otherwise uses and\/or benefits from the Services, with the authority of or through the Client;<\/p>\n When we refer to \u2018Client\/s\u2019, we mean the person or entity to whom we provide Services pursuant to a service agreement duly executed and signed with us, who instructs us to register for and maintain an account with the relevant SaaS provider for the benefit of such person or entity (or other Account User or connected organisation), thereby acting to procure or facilitate access to\/use of the relevant SaaS application, and who typically receives from us additional value-added services associated with or in relation to the same, and, where the context permits, includes any person or entity on whose behalf or for the benefit of whom that person or entity enters into such service agreement with us;<\/p>\n When we refer to \u2018Data Subject\u2019, we mean any identified or identifiable natural person whose personal data is being processed by us; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to, amongst other things, an identifier such as a name, an identification number, location data, bank account and payment information, an online identifier or to one or more factors specific to that natural person; If you are no longer identified or identifiable and your personal data has been anonymized, this Privacy Policy shall not apply;<\/p>\n When we refer to \u2018personal data\/information\u2019, we mean any information relating to a Data Subject;<\/p>\n When we refer to \u2018processing\u2019, we mean, amongst other things, any operation\/s performed on personal data, whether or not by automated means, such as collection, recording, organisation, storage, alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction;<\/p>\n When we refer to \u2018SaaS applications\/solutions\u2019, we mean software-as-a-service, hence a creation of cloud computing whereby cloud-based software is licensed by independent software vendors and distributed on a subscription basis, and is centrally hosted;<\/p>\n When we refer to \u2018SaaS provider\/s\u2019, we mean a developer\/vendor of SaaS applications with whom we enjoy authorised partner\/reseller status;<\/p>\n When we refer to \u2018Service\/s\u2019, we mean the business solution which we offer to our Clients, which comprises procuring or facilitating the registration for and maintenance of an account with the relevant SaaS provider for the benefit of the Client (or other Account User or connected organisation), thereby enabling access to\/use of the relevant SaaS application for\/by the Client and other Account Users or connected organisations, as well as the provision of value-added services associated with or in relation to the same including software customization, implementation, data migration, and maintenance and support services;<\/p>\n When we refer to \u2018Website\u2019, we mean Scope\u2019s internet site at the domain https:\/\/www.scope.mt<\/a> \u00a0through which Website Users can obtain information about us and what we do, or may otherwise contact us and\/or raise support tickets through Scope\u2019s support policy;<\/p>\n When we refer to \u2018Website User\u2019, we mean any person who visits our Website.<\/p>\n Applicable Data Protection Legislation<\/u><\/em><\/p>\n As an entity established in Malta, and therefore in the EU, the main data protection laws that are applicable to us in so far as your personal data is concerned, are the General Data Protection Regulation (the \u2018GDPR\u2019), namely, Regulation (EU) 2016\/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, repealing Directive 95\/46\/EC, which Regulation became directly applicable on 25th May 2018; and Chapter 586 of the Laws of Malta, namely the Data Protection Act (the \u2018DPA\u2019), as amended or supplemented from time to time, including the various subsidiary legislation issued under the same, which DPA implements and further specifies the relevant provisions of the GDPR and repeals and replaces Chapter 440 of the Laws of Malta, the latter being the former local legislation governing data protection.<\/p>\n This Privacy Policy<\/u><\/em><\/p>\n We act as a \u2018controller\u2019 in relation to your personal data when we process such data in our own right, for our own purposes. This includes the processing of personal data relating to our officers and employees, Website Users, our existing or potential Clients, our recognized or potential business partners, and suppliers.<\/p>\n We act as a \u2018processor\u2019 in relation to your personal data when we process such data in our quality as processor, acting for and on behalf of a data controller who controls and determines the purposes and means of processing of personal data. We may also be acting as \u2018sub-processor\u2019 when we are appointed by another processor to assist in the processing of personal data by the latter. Our role as processor or sub-processor, as the case may be, may therefore include the processing of personal data relating to officers, employees, suppliers, third-party service providers or clients of our Clients, or possibly officers, employees, suppliers, third-party service providers or clients of the clients of our Clients, hence including organisations or persons that are permitted access to\/use of the relevant SaaS application made available \u00a0and\/or supported by us or otherwise benefit from the Services with your authority or as a result of your use of the Services (\u2018connected organisations\u2019). We are considered as processors since we may carry out certain activities which may include the collection, recording, organisation, storing, use, transmission, retrieval, deletion or other form of processing of personal data. As processors, we shall process your personal data strictly on the documented instructions received from the controller.<\/p>\n This Privacy Policy attempts to describe what, why and the legal basis for processing your personal data, the relevant security measures to protect the privacy of your personal data and prevent the unauthorised access to or processing of your personal data, as well as details regarding the various rights you are entitled to exercise at law, as Data Subjects, in relation to your personal data.<\/p>\n We assume responsibility for our processing activities, and shall be accountable to Data Subjects, in our quality as a controller and\/or processor, as the case may be, in accordance with and to the extent applicable, as prescribed by applicable data protection legislation.<\/p>\n Personal Data and Data Subjects<\/u><\/em><\/p>\n When we refer to \u2018personal data\u2019 we mean any data in relation to you, assuming you are an identified or identifiable natural person. Therefore, if any data we process can be linked or traced back to you, in consequence of us being in possession of, say, your first name\/last name, email address, physical personal address, telephone\/mobile number, IP Address, unique device IDs, bank account details and other payment information, and so on, this data warrants protection under applicable data protection legislation.<\/p>\n If you can no longer be identified\/identifiable (for example, when personal data has been aggregated and anonymised) then this Privacy Policy no longer applies. However, where it is not possible or feasible for us to make use of anonymous and\/or anonymised data, we are nevertheless committed to protecting your privacy and the security of your personal data at all times.<\/p>\n <\/p>\n Furthermore, please keep in mind that information relating to legal persons does not amount to personal data as intended by applicable data protection legislation and therefore falls outside the scope of this Privacy Policy. This Privacy Policy however applies where natural persons are individually identified or identifiable (including possibly physical persons who are themselves partners, shareholders, directors and other officers, and the like, of any such legal persons) and the information relates to such individuals in their personal capacity in so far as they would qualify as Data Subjects in terms of law and must therefore be afforded all data protection rights in accordance with applicable data protection legislation.<\/p>\n <\/p>\n Lawful Processing and Legal Basis for processing Personal Data<\/u><\/em><\/p>\n We only process personal data, received from you or otherwise requested and\/or obtained from other sources, through lawful means, as described below, that is absolutely relevant and limited to what is necessary in relation to the purpose for which it is processed, and, only if we:<\/p>\n When we ask for your personal data, you are at liberty to provide or otherwise refuse to provide the same to us, however should you decline to provide us with the necessary data that we have requested, this may restrict functionality of the Website or our ability to provide you with the Services.<\/p>\n How do we collect your Personal Data?<\/u><\/em><\/p>\n We may request or obtain or come into possession of personal information from different sources, provided that, we have a valid lawful basis for doing so:<\/p>\n \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 <\/strong><\/p>\n What Categories of Personal Data do we process and Why do we process it?<\/u><\/em><\/p>\n The categories and types of information we collect about you or otherwise process can be broadly classified as: (i) personal information (ii) contact information (iii) transactional information including incident history and data resulting from your access to\/use of the relevant SaaS application made available and\/or supported by us and the provision of value-added services including technical support services (iv) billing information and (v) behavioural information obtained as a result of using our Website or in the course of providing our Services to you.<\/p>\n <\/p>\n More specifically, the following data (some of which does not necessarily qualify as personal data as such) may be processed for the purposes outlined below:<\/p>\n <\/p>\n <\/p>\n <\/p>\n By processing this information, we are able to provide the Services, as well as administer and manage your relationship with us, including:<\/p>\n <\/p>\n In addition please note that our Website and Services are intended for a general audience interested in using or benefiting from a range of cloud-based business solutions made available and\/or supported by us which primarily focus on accounting, billing, job management and other financial management tools, as well as email, calendar and appointments management, and POS and inventory tools. For this reason, we do not knowingly collect or process information with regard to children or other individuals who are not legally capable of using or benefiting from such tools. Nor do we knowingly collect or process special categories of personal data as understood by applicable data protection legislation. If we become aware that we have collected or otherwise processed information with regard to a child or information that is otherwise captured by the \u2018special category of data\u2019 provisions, we will promptly do our utmost to delete such data, save where and to the extent that we are legally obligated to retain such data in order to comply with applicable data protection legislation or other applicable legislation. If you believe that we have mistakenly or unintentionally collected or otherwise processed information with regard to a child or special categories of personal data, please\u00a0contact us<\/a>.<\/p>\n <\/p>\n Whom do we share your Personal Data with?<\/u><\/em><\/p>\n Please note that the information collected or otherwise processed by us is strictly intended for the sole use by us in the manner and for the purpose\/s afore-described, and, it is not shared, disclosed, transmitted or otherwise made available, unless and save to the extent as otherwise provided in this Privacy Policy, nor is it leased or sold in any manner, to any other person or organisation. It is not our business to do so and we want to earn your trust and confidence.<\/p>\n However, there will be times when we may receive from or share, disclose, transmit, exchange or otherwise make available personal data, with\/to third parties, including:<\/p>\n <\/p>\n <\/p>\n <\/p>\n <\/p>\n <\/p>\n <\/p>\n <\/p>\n Use of Processors and Sub-processors<\/u><\/em><\/p>\n Where we are acting as the controller of personal data, we may appoint other processors to assist us in the processing of personal data on our behalf. Furthermore, the appointment by the processor of further sub-processors along the chain will require our prior written approval in our quality as controller. Where we act as controller, we shall obtain sufficient safeguards from any such other processors appointed by us as to ensure their compliance with applicable data protection obligations, and shall procure that, any sub-processors appointed by such other processors along the chain are also bound by the same data protection obligations binding the processor.<\/p>\n Where we act as a processor, it is further understood that, by providing us with or allowing us to access or process personal data relating to individuals other than yourself (where applicable), you are letting us know that you have obtained the necessary authority for you to disclose, procure, make available or otherwise permit us to access, use or process that data in the manner described in this Privacy Policy. We may also appoint sub-processors to assist us in our processing activities, provided that, no sub- processors will be engaged by us unless we are confident that the controller has authorised such processing.<\/p>\n We shall inform the controller of any intended changes concerning the addition or replacement of other sub-processors so as to give the opportunity to the controller to object to such changes. We shall ensure that any sub-processors appointed by us are bound by the same data protection obligations imposed on us by the controller in our quality as processor, and shall procure that, any such sub-processor imposes the same data protection obligations on other sub-processors appointed along the chain. This includes the provision of sufficient guarantees by the sub-processor toward the implementation of appropriate technical and organisational measures to meet the requirements of applicable data protection legislation. We shall remain answerable to the controller for the failure or improper performance of our sub-processors\u2019 data protection obligations.<\/p>\n We keep an up-to-date list of our (sub) processors:<\/p>\n <\/p>\n Where do we store your Personal Data?<\/u><\/em><\/p>\n We do not host or store any of your data on our own data centre. We use the business cloud services of different vendors whose servers are located in different countries located in the EU\/EEA or possibly even in third countries after we have ensured that appropriate safeguards are put in place so as to protect your personal data and do not undermine your rights under applicable data protection legislation.<\/p>\n International Data Transfers<\/u><\/em><\/p>\n When we share your personal data with third countries, hence countries outside of the EEA (European Economic Area), we ensure that appropriate safeguards are put in place so as to protect your personal data and do not undermine your rights under applicable data protection legislation.<\/p>\n Consequently, such data shall only be shared with, transferred to or processed in countries that have been identified as providing an adequate level of protection, equivalent to EU standards, as so determined by the EU Commission, or, save where derogations for specific situations may otherwise be invoked in accordance with applicable legislation, by otherwise making sure that appropriate safeguards are met including via the adoption of approved transfer mechanisms by\/between the relevant data recipient\/importer such as via the acceptance and use, in their entirety, of the European Commission\u2019s Standard Contractual Clauses (accessible on the following URL: https:\/\/commission.europa.eu\/law\/law-topic\/data-protection\/international-dimension-data-protection\/standard-contractual-clauses-scc_en<\/a>), or the employment of binding corporate rules for transfers within group companies, where applicable (accessible on the following URL: https:\/\/commission.europa.eu\/law\/law-topic\/data-protection\/international-dimension-data-protection\/binding-corporate-rules-bcr_en#approval-of-binding-corporate-rules<\/a>).<\/p>\n What are your rights as Data Subjects?<\/u><\/em><\/p>\n\n
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