Privacy Policy

1. Data Controller

• Legal Entity: Heaventree Ltd.
• Jurisdiction: Gibraltar
• Registered Address: Suite 4.3.02, Block 4, Eurotowers, Gibraltar, GX111AA
• Contact Email (Privacy & Data Requests): info@scriibl.com

Heaventree Ltd. is the data controller for the purposes of applicable data protection laws, including the EU General Data Protection Regulation ("GDPR").

2. Personal Data We Collect

a) Information You Provide Directly

We may collect:

• Name
• Email address
• Account credentials
• Billing and subscription details
• Content you upload or publish
• Communications with support

This data is collected when you create an account, publish content, subscribe, contact us, or otherwise interact with Scriibl.

Legal basis: Contract, Legitimate Interests, or Consent (depending on context)

b) Automatically Collected Information

When you use Scriibl, we may automatically collect:

• IP address
• Device and browser type
• Access times and pages viewed
• Usage and performance metrics

This data is used for security, fraud prevention, analytics, and service improvement.

Legal basis: Legitimate Interests

c) Cookies and Similar Technologies

Scriibl uses cookies and similar technologies to operate securely and improve functionality.

• Strictly necessary cookies are always active
• Analytics or marketing cookies are used only where legally permitted and subject to your consent

You can manage cookie preferences via our cookie banner or browser settings. Full details are provided in our Cookie Policy.

Legal basis: Consent (where required), Legitimate Interests (essential cookies)

3. How We Use Personal Data

We use personal data to:

• Provide and operate the Scriibl platform
• Manage user accounts and subscriptions
• Process payments and prevent fraud
• Communicate with users and provide support
• Improve platform functionality and performance
• Comply with legal and regulatory obligations

We do not sell personal data.

4. Payments

Payments are processed by third-party payment providers (such as Stripe). Heaventree Ltd. does not store full payment card details.

Payment providers act as independent data controllers or processors under their own privacy policies.

5. User-Generated Content

Content you publish on Scriibl may contain personal data. You are responsible for ensuring you have the legal right to publish such content.

Heaventree Ltd. acts as a hosting provider, not a publisher, in relation to user-generated content.

6. Legal Bases for Processing

We process personal data based on:

• Contract – to provide the services you request
• Legitimate Interests – to operate, secure, and improve Scriibl
• Consent – where required (e.g. marketing, non-essential cookies)
• Legal Obligation – where required by law

7. Data Sharing

We may share personal data with:

• Hosting and infrastructure providers
• Payment processors
• Analytics and security providers
• Legal or regulatory authorities where required

All service providers are contractually required to protect personal data and process it only on our instructions.

8. International Data Transfers

Scriibl is operated globally. Personal data may be transferred outside the EEA.

Where required, transfers are safeguarded using:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions (where applicable)
• Additional technical and organisational safeguards

9. Data Retention

We retain personal data only as long as necessary for the purposes for which it was collected, including legal, accounting, and security requirements.

Typical retention periods include:

• Account data: for the duration of the account
• Billing records: as required by applicable law
• Support communications: limited retention for service quality and dispute resolution

Data is securely deleted or anonymised when no longer required.

10. Data Security

We implement appropriate technical and organisational measures, including:

• Encryption (SSL/TLS)
• Access controls
• Secure hosting environments
• Regular security reviews

No system is completely secure, but we take reasonable steps to protect personal data.

11. Your Rights

Where applicable under GDPR, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion
• Restrict or object to processing
• Data portability
• Withdraw consent at any time

Requests can be submitted to: info@scriibl.com

You also have the right to lodge a complaint with your local data protection authority.

12. Marketing Communications

You will only receive marketing communications where legally permitted. You may unsubscribe at any time using the link provided or by contacting us.

13. Children's Privacy

Scriibl is not intended for children under 16. We do not knowingly collect personal data from children. If such data is identified, it will be deleted promptly.

14. EU Digital Services Act (DSA)

For EU users, Scriibl operates as an intermediary hosting service under Regulation (EU) 2022/2065.

Heaventree Ltd. does not engage in proactive monitoring of user content but will act upon valid notices of illegal content in accordance with applicable law.

15. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on scriibl.com.