This policy explains what we collect, why, and the choices you have. We’ve built Scamblare to meet the strictest of the rules that apply to us — the EU and UK GDPR, Japan’s APPI, and the U.S. CAN-SPAM Act — and to collect as little as possible.
Who we are
The data controller is Clouridge Ltd., with its registered office at 2-25-1-407 Iriya, Adachi-ku, Tokyo 121-0836, Japan. For any privacy request or question, contact us at privacy@scamblare.com.
What we collect
- Email address — only if you subscribe to our newsletter. (While we are in our initial launch phase, email sign-up is not yet open and no email addresses are collected.)
- Privacy-friendly analytics — aggregate, non-identifying data about page views, so we can see what’s useful. This does not use cookies and does not build a profile of you.
Why we use it, and our legal basis
- Newsletter — to send the emails you asked for. Legal basis: your consent, given at sign-up and confirmed by double opt-in.
- Site improvement and analytics — to understand what content helps. Legal basis: consent or our legitimate interest in improving the site, using data that does not identify you.
We do not use your data for any unrelated purpose, and we never sell it.
Your rights
Wherever you live, you can ask us to show you the personal data we hold, correct it, delete it, restrict or object to how we use it, or provide it in a portable form. EU and UK readers have these rights under the GDPR; readers in Japan have equivalent rights of disclosure, correction, and suspension of use under the APPI. We handle all of these requests through the same contact above.
How long we keep it
We keep your email only until you unsubscribe. After that, we retain the minimum needed on a suppression list, purely to make sure we don’t email you again.
Who else is involved
We use a small number of trusted processors to run the service — an email provider (beehiiv) for the newsletter, and a privacy-friendly analytics provider. They process data on our behalf under their own data-protection terms.
International data transfers
Because our processors and readers are global, your data may be transferred between the EU/UK, the United States, and Japan. Where it is, we rely on appropriate safeguards (such as Standard Contractual Clauses) to protect it.
Cookies and analytics
By default we use cookieless, privacy-friendly analytics, so there’s no tracking cookie and no consent banner to click through — the lowest-data option. If we ever introduce analytics that rely on cookies, we will ask for your consent first, as EU and UK rules require.
Children
Scamblare is not intended for children under 13 (or under 16 where local law requires), and we do not knowingly collect their data.
Contact
For any request about your data — access, correction, deletion, or a question — email privacy@scamblare.com, or write to Clouridge Ltd., 2-25-1-407 Iriya, Adachi-ku, Tokyo 121-0836, Japan.