Scythia Brands Ltd
Company Number 13092163
9th Floor, 107 Cheapside, London, EC2V 6DN, United Kingdom

1 INTRODUCTION

1.1 Important information and who we are

Welcome to Scythia Brands Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).
At Scythia Brands Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your
privacy and Personal Data in compliance with the United Kingdom General Data Protection
Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and
regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy
Policy will tell you about your privacy rights, how the law protects you, and inform our
employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

  • Suppliers
  • Business contacts
  • Employees/Staff Members
  • Careers Candidates
  • and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data
processed at any time by us.

1.2 Who is Your Data Controller

Scythia Brands Ltd is your Data Controller and responsible for your Personal Data. We are not
obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed
one at this time. Therefore, any inquiries about your data should either be sent to us on email
at [email protected] or sent in a letter to 9th Floor, 107 Cheapside, London, EC2V
6DN, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office
(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.


1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with
your data on our behalf (known as “Processors”). Therefore, the responsibilities described
below may be assigned to an individual, or may be taken to apply to the organisation as a
whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid
out in the GDPR (see 2.2 below for more information on those bases);

Ensure that Processors authorised to process Personal Data have committed
themselves to confidentiality or are under an appropriate statutory obligation of
confidentiality;

Implement appropriate technical and organisational measures to ensure a level of
security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging
another Processor;

Assist the Controller in the fulfilment of the Controller’s obligation to respond to
requests for exercising the data subject’s rights;

Make available to the Controller all information necessary to demonstrate compliance
with the obligations laid down in the GDPR and allow for and contribute to audits,
including inspections, conducted by the Controller or another auditor mandated by the
Controller;

Maintain a record of all categories of processing activities carried out on behalf of a
Controller;

Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to
Personal Data does not process Personal Data except on instructions from the
Controller; and

Notify the Controller without undue delay after becoming aware of a Personal Data
Breach;

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

“Personal Data” means any information about an individual from which that person can be
identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we
have grouped together below. Not all of the following types of data will necessarily be
collected from you but this is the full scope of data that we collect and when we collect it from
you:

  • Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.

We do not collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health, and genetic and
biometric data). Nor do we collect any information about criminal convictions and offences.


2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing
of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when you
tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’
to a service.

“Contractual Obligations”: We may require certain information from you in order to
fulfil our contractual obligations and provide you with the promised service.

“Legal Compliance”: We’re required by law to collect and process certain types of data,
such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be
able to meet our legitimate interests – this covers aspects that can be reasonably
expected as part of running our business, that will not have a material impact on your
rights, freedom or interests. Examples could be your address, so that we know where to
deliver something to, or your name, so that we have a record of who to contact moving
forwards.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table
containing the different types of Personal Data we collect and the lawful basis for processing
that data. Please refer to section 2.2 for more information on the lawful basis listed in the
table below.

Examples provided in the table below are indicative in nature and the purposes for which we
use your data may be broader than described but we will never process your data without a
legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

3.2 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the
new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 How Does Scythia Brands Ltd Protect Customers’ Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate
disclosure. We implement a variety of security measures to ensure the security of your
Personal Data on our systems, including data is collected through a secure https protocol. Any
Personal Data collected by us is only accessible by a limited number of employees who have
special access rights to such systems and are bound by obligations of confidentiality. If and
when we use subcontractors to store your data, we will not relinquish control of your Personal
Data or expose it to security risks that would not have arisen had the data remained in our
possession. However, unfortunately no transmission of data over the internet is guaranteed to
be completely secure. It may be possible for third parties not under the control of Scythia
Brands Ltd to intercept or access transmissions or private communications unlawfully. While
we strive to protect your Personal Data, we cannot ensure or warrant the security of any
Personal Data you transmit to us. Any such transmission is done at your own risk. If you
believe that your interaction with us is no longer secure, please contact us.

4.2 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other
rights). However, if your request is clearly unfounded, we could refuse to comply with your
request.

We may need to request specific information from you to help us confirm your identity and
ensure you have the right to access your Personal Data (or to exercise any of your other
rights). This is a security measure to ensure that Personal Data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.

5 YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may also share Personal Data with interested parties in the event that Scythia Brands Ltd
anticipates a change in control or the acquisition of all or part of our business or assets or with
interested parties in connection with the licensing of our technology.

If Scythia Brands Ltd is sold or makes a sale or transfer, we may, in our sole discretion,
transfer, sell or assign your Personal Data to a third party as part of or in connection with that
transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the
further use of your Personal Data. In all other situations your data will still remain protected in
accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to
enforce our terms or this Privacy Policy.

6 HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we
collected it for. We may retain your Personal Data for a longer period than usual in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship
with you.

7 INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions outside
the US where Scythia Brands Ltd has facilities. We are currently storing data in the EU and so, by
using Scythia Brands Ltd, you are permitting and consenting to the transfer of information, including
Personal Data, outside of the US.

8 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This version is
dated 1 October 2021. By using Scythia Brands Ltd, you consent to the collection and use of data by
us as set out in this Privacy Policy. Continued access or use of Scythia Brands Ltd will constitute your
express acceptance of any modifications to this Privacy Policy.

9 INTERPRETATION

All uses of the word “including” mean “including but not limited to” and the enumerated examples
are not intended to in any way limit the term which they serve to illustrate. Any email addresses set
out in this policy may be used solely for the purpose for which they are stated to be provided, and
any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the
right to not respond to emails, even if they relate to a legitimate subject matter for which we have
provided an email address. As a matter of common sense, you are more likely to get a reply if your
request or question is polite, reasonable and there is no relatively obvious other way to deal with or
answer your concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of Scythia Brands Ltd, waive rights or make
representations (whether contractual or otherwise). If anything contained in an email from a Scythia
Brands Ltd address contradicts anything in this policy, our terms or any official public announcement
on our website, or is inconsistent with or amounts to a waiver of any Scythia Brands Ltd rights, the
email content will be read down to grant precedence to the latter. The only exception to this is
genuine correspondence expressed to be from the Scythia Brands Ltd legal department.