Effective Date: June 13th, 2019
When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
When we refer to “Scapegrace”, we mean the Scapegrace entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Things you create or provide to us
Scapegrace may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals granted access to an Organisation by a Customer (“Authorised Users”) routinely submit Customer Data to Quitch when using the Services.
- Other Information. Scapegrace also collects, generates and/or receives Other Information:
- Quitch and Account Information. To create or update a Quitch account, you or your Customer (e.g., your employer) supply Scapegrace with an email address, display name, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Scapegrace (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
- Usage Information.
- Services Metadata. When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way Authorised Users work. For example, Scapegrace logs the Organisation, Course Content, features and links you interact with, the types of files shared and what Third Party Services are used (if any).
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and our cookie data.
- Device information. Scapegrace collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Scapegrace may also collect location information from devices in accordance with the consent process provided by your device.
- Third Party Services. Customer can choose to permit or restrict Third Party Services for their Workspace. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorised Users to enable and disable these integrations for their Organisation. Once enabled, the provider of a Third Party Service may share certain information with Scapegrace. For example, if a cloud storage application is enabled to permit files to be imported to an Organisation, we may receive user name and email address of Authorised Users, along with additional information that the application has elected to make available to Scapegrace to facilitate the integration. Authorised Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Scapegrace. When a Third Party Service is enabled, Scapegrace is authorised to connect and access Other Information made available to Scapegrace in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
- Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorised User chooses to import is collected when using the Services.
- Third Party Data. Scapegrace may receive data about organisations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to post codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional Information Provided to Scapegrace. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Quitch.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Organisation setup details, is not provided, we may be unable to provide the Services. Due to the operational requirements of the Platform it is not practicable for you to use a pseudonym or remain anonymous by not disclosing your identity to us.
How We Use Information
Customer Data will be used by Scapegrace in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Scapegrace is a processor of Customer Data and Customer is the controller. Customers may, for example, use the Services to grant and remove access to an Organisation, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Scapegrace uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Scapegrace uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorised User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools and additional features. Scapegrace tries to make the Services as useful as possible for specific Organisations and Authorised Users. For example, we may improve functionality by using Other Information to help determine and rank the relevance of content or expertise to an Authorised User, make Services suggestions based on historical use and predictive models, identify organisational trends and insights, to customise a Services experience or create new productivity features and products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Quitch. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Scapegrace may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
How We Share And Disclose Information
This section describes how Scapegrace may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Customer Data, and Scapegrace does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Scapegrace will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Displaying the Services. When an Authorised User submits Other Information, it may be displayed to other Authorised Users in the same or connected Organisations. For example, an Authorised User’s email address may be displayed with their Quitch profile.
- Collaborating with Others. The Services provide different ways for Authorised Users working in independent Organisation to collaborate, such as shared leaderboards. Other Information, such as an Authorised User’s profile Information, may be shared, subject to the policies and practices of the other Organisation(s).
- Customer Access. Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Organisation activity, or accessing or modifying your profile details. For information about your Organisation settings, please contact firstname.lastname@example.org.
- Scapegrace Employees. Scapegrace its employees, officers, directors, agents, contractors, and related bodies corporate may access, modify or restrict access to Customer Data and Other Information as required to perform their duties.
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth in Subprocessors.
- Corporate Affiliates. Scapegrace may share Other Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to Scapegrace’s Business. If Scapegrace engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of Scapegrace’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Scapegrace customer the average amount of time spent within a typical Organisation.
- To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any Australian or other laws, regulation or legal process. Please see the Data Request Policy to understand how Scapegrace responds to requests to disclose data from government agencies and other sources.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Scapegrace or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Scapegrace may share Other Information with third parties when we have consent to do so.
Other than this, we will only disclose Information to an unrelated third party after receiving your consent to such disclosure. We will not sell any of your personal information to third parties for direct marketing purposes.
Transfer of information
We may transfer your personal information and process it outside your country of residence and/or outside EU or the European Economic Area (EEA), wherever Scapegrace, its Processors (Scapegrace’s affiliates and service providers) and, if applicable, the Customer operate.
Those countries include:
- The United States of America;
You acknowledge that we may transfer your personal information and process it outside your country of residence and/or outside the European Economic Area (EEA) (where applicable), wherever Scapegrace, its Subprocessors and, if applicable, or our Customers operate.
You further acknowledge that there are inherent risks in transmitting information, including the risk that information sent may be intercepted, corrupted or modified by third parties. No transmission of information via the internet can be guaranteed to be completely secure. As a result, we do not warrant the security of any information which is transmitted to us or from us to our Subprocessors or from our Subprocessors to us. If you are in the EEA you acknowledge that as a result of the transmission outside of the EEA and a possible absence of an adequacy decision by the European Commission there may be no adequate level of data protection and your rights may not be enforceable.
Scapegrace takes security of data very seriously. Scapegrace works hard to protect Other Information you provide from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, Scapegrace cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others. It is your responsibility to protect the security of your login information. Please help keep your account safe by using a strong password.
To the extent prohibited by applicable law, Scapegrace does not allow use of our Services and Websites by anyone younger than 16 years old without parental consent. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
Data Protection Officer
To communicate with our Data Protection Officer, please email email@example.com.
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Scapegrace is the processor of Customer Data and the controller of Other Information. Scapegrace, an Australian company based in Melbourne, Australia is the controller of Other Information and a processor of Customer Data relating to Authorised Users who use the Quitch service.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the information and tools provided in your Quitch account. If you cannot use the information and tools provided, contact Customer for additional access and assistance.
To the extent that Scapegrace’s processing of your Personal Data is subject to the General Data Protection Regulation GDPR, Scapegrace relies on its legitimate interests, described above, to process your data. Scapegrace may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Scapegrace’s use of your Personal Data for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Scapegrace’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Irish Data Protection Commissioner, which is Scapegrace’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:
If you wish to make a complaint in connection with the GDPR you can contact the data protection authority in your state which is a member of the EU. Our Data Protection Officer can provide you with the details of the authority.
Scapegrace Pty Ltd
PO Box 2279
Hawthorn Post Office
Victoria, 3122, Australia
We will endeavour to respond to your enquiries as quickly as possible. We aim to resolve complaints within (5) business days but some cases may take longer to resolve. If your complaint takes longer to resolve we will inform you about that and keep you updated at regular intervals.
If you wish to make a complaint in connection with the APP you can contact the Commissioner at: