Definitions
In this Privacy Notice, the following terms shall have the meanings ascribed to them:
Administering Authority: This could be a Court of Law, Department of Corrections, or other legal authority with whom you may have a legal obligation.
PII: Personal Identifiable Information; also known as Personal Data; any information relating to an identified or identifiable natural person. We may collect and process personal data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide personal data when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.
Data Subject: A natural person who is the subject of PII collection. Also known as a PII principal. Also known as a Client.
Processing: Any operation or set of operations performed on PII, including collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure, transmission, dissemination, or destruction.
Controller: A natural or legal person, public authority, agency, or another body that determines the purposes and means of PII processing.
Processor: A natural or legal person, public authority, agency, or another body that processes PII on behalf of the controller.
Consent: Freely given, specific, informed, and unambiguous indication of the data subject’s wishes, either by a statement or by a clear affirmative action.
Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to PII.
Monitoring Hardware: Monitoring hardware includes Continuous Alcohol Monitoring Bracelets, GPS tracking Bracelets, and all other communications accessories associated with them.
Alcohol Monitoring Systems, Inc.: This entity is a wholly owned subsidiary of LMG Holdings, Inc., and specializes in devices and services for continuous alcohol monitoring, GPS tracking, and their associated SaaS applications.
SCRAM Systems: SCRAM Systems is a registered DBA for Alcohol Monitoring Systems, Inc. and is a federally registered trademark. It is also used for branding purposes to identify the entire family of products and services belonging to Alcohol Monitoring Systems, Inc. and its affiliates.
AMS UK LTD.: Operating exclusively in the U.K., is a wholly owned subsidiary of Alcohol Monitoring Systems, Inc., and specializes in devices and services for continuous alcohol monitoring and their associated SaaS applications.
Data Security and Privacy Safeguards
SCRAM Systems endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with SCRAM Systems, Administering Authorities, and the practices described in this Privacy Statement. SCRAM Systems’ security and privacy practices are governed by adherence to a Privacy Information Management System (PIMS) in accordance with ISO 27001 and ISO 27701. Among the safeguards used is encryption of your PII data in transit, at rest, and in process. However, because no electronic transmission or storage of information can be entirely secure, SCRAM Systems cannot guarantee the security or privacy of your information, to the extent permitted by applicable law.
SCRAM Systems’ Role as a Data Controller
For marketing to visitors to our websites, SCRAM Systems is a data controller and determines the purpose and means of PII processing.
The Data we collect about You:
When you access our sites, we may collect, or you may provide us with personal data. We may collect, use, store, and transfer different types of personal data about you, which we have grouped together as follows:
- Identity data including your first name, last name, title, your organization and job role, or other identifiers;
- Contact data including your residential address, email address, and telephone numbers;
- Technical data including your internet protocol (IP) address, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other details about the devices you use to access our sites;
- Usage data including information about how you use our sites; and
- Marketing and communications data including your preferences in receiving marketing materials and updates from us and third parties and your communication preferences.
Your consent comes from your use of our websites by voluntarily submitting your contact information.
We also collect, use, and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered to be personal data in law as it does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing specific features. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, the combined data is personal data, and we deal with it in accordance with this privacy notice.
We do not knowingly collect details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, sexual orientation, or genetic or biometric data (known as “special categories of data”), or any information about criminal convictions or offenses through our sites.
Human Resources data
SCRAM Systems collects Personal Data from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. SCRAM Systems may also collect sensitive data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status.
SCRAM Systems process Human Resources Data for different business purposes including:
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, compensation analysis, including monitoring overtime and compliance with labour laws;
- Job grading activities;
- Performance and employee development management;
- Organizational development and succession planning;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
How Your Personal Data is Collected:
- Direct interaction with you. You may give us identity and contact data by filling in forms on our sites or by communicating with us by mail, telephone, email or otherwise. This includes data you provide when you request information about our products and services, contact us in relation to our blog, refer a client, download resources, or use interactive features on our site or social media applications.
- Third parties and publicly available sources. We may receive personal data about you from other parties and/or from public sources, as set out below:
- technical data from analytics providers such as Google Analytics and Pardot and advertising networks such as Google Ads and Remarketing, Facebook Pixel, the X (Twitter) Conversion Tracker, and the LinkedIn Insight Tag;
- contact information about you from business partners, events, conferences, or industry tradeshows;
- other individuals under our “refer a client” form.
- Personal Data collected via automated means[MF1] . We and our service providers may collect data automatically in a variety of ways, including:
- Your browser or device. Certain data is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this data to ensure that the Services function properly.
- Cookies and other tracking technologies. We and our service providers use various technologies, including cookies, pixels, and web beacons, and similar online tracking technologies (collectively, “cookies”) to collect data about you when you interact with our Services, including information about your browsing behavior and user experience. First and third-party cookies allow us to collect such data as browser type, time spent on the Services, pages visited, language preferences, unique identifiers, content you view, click on, or share, screen actions, and other traffic data.
We and our service providers use the data for security purposes, to power the interactive features of our Services, to facilitate navigation, to display information more effectively, to personalize your experience, to develop and improve the performance, functionality, and design of the Services, for advertising, and to help keep the Services free of bugs or errors. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding the Services. Cookies are also used to track the actions of users of the Services (including email recipients), conduct advertising, measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. [MF2]
If you do not want data collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services, and you also may not receive advertising or other offers from us that are relevant to your interests and needs.
We and third-party service providers may use the following types of cookies[MF3] :
- Essential cookies. Some cookies are strictly necessary to make our Services available to you. For example, to provide login functionality or to allow you to fill out forms. We cannot provide you with the Services without this type of cookie.
- Analytics cookies. We use analytics cookies to help us understand how our Services perform and function, track user interactions with the Services, operate, maintain and improve our Services, and to track whether you open emails that we send to you. We engage third-party analytics services, which use tracking technologies to collect and analyze information about use of the website and report on activities and trends. These services also collect information regarding the use of other websites, apps, and online resources. One of our analytics service providers is Google. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
- Targeted Advertising cookies. We work with third party advertising partners such as Google Ads and Bing Ads to show you ads that we think may interest you. These advertising partners may set up and access their own cookies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. To learn how to opt out of such activities, please see the section on “Targeted Advertising” below.
More information about the individual cookies we use and the purposes for which we use them is set out in the table below: