ScriptRunner Loop Privacy Policy

Date: 31 March 2025 

The ScriptRunner Loop Online Engagement Platform is owned by The Adaptavist Group (“TAG”) and is powered by a technology platform provided by CircleCo, Inc. (“Circle”). For further details about Circle, please refer to their website here: https://circle.so/  

This privacy policy (“Privacy Policy”) explains how the ScriptRunner Loop Online Engagement Platform (“we,” “us,” “our”, “Platform” and/or “ScriptRunner Loop”) collects, uses, discloses or otherwise processes Personal Data  from individuals (“you” and/or “your”) who access and use our Platform  either online or through other downloadable applications (collectively, the “Community”). Beyond the Privacy Policy, your use of the Community is also subject to our Terms of Service.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Amendments to this Privacy Policy will be effective upon posting and operate as a condition of your continued engagement with or continued use of the Platform.  

It is your responsibility to check this page and to review the Privacy Policy whenever you access ScriptRunner Loop or otherwise interact with us to stay informed about our information practices and the choices available to you. If you do not consent to the Processing of your Personal Data in accordance with this Privacy Policy, or wish to withdraw consent to such processing, please refrain from, or stop using the Platform. 

1. Definitions

"Personal Data Breach," "Controller," "Processor", "Data Subject", "Personal Data", "Processing," "Special Category Data". "Profiling" "Pseudonymisation" "Consent", and "appropriate technical and organisational measures” as used in this Policy shall have the meanings given in the GDPR irrespective of whether GDPR, UK GDPR, or U.S. Data Protection Law applies. For the avoidance of doubt, “Personal Information” shall have the same meaning as “Personal Data” for the purposes of this Privacy Policy. 

"Data Protection Law"  any privacy law applicable to the Processing of Personal Data under this Privacy Policy from time to time, including the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR, the UK Data Protection Act 2018, the UK Privacy and Electronic Communications Regulations 2003 (SI 2003/2426), the Swiss Federal Data Protection Act of 2023 (“FADP”) and its Ordinance,  the U.S. Data Protection Law (as defined hereinafter) and any other legislation, regulatory requirements, guidance or code of practice issued by a competent regulator or supervisory body.  

“U.S. Data Protection Law” means data protection or privacy laws applicable to Personal Data in force within the United States, including the California Consumer Privacy Act 2020 (“CCPA”).

2. Personal Information We Collect

A. Personal Information You Provide to Us

Registration and Profile Information. When you open an account with us in view of joining ScriptRunner Loop (“Account”), we will ask you to provide us with identifiers and contact information such as your name, email address, company, country of residence, and any other Personal Information as required as part of the Account registration. 

Communications. We may also collect identifiers, such as your name, email address, and other information you choose to provide, when you participate in any interactive features of ScriptRunner Loop (like send us a message through the Platform features), fill out a form, publish posts and/or comments on the Platform, participate in a contest or promotion, request customer support, or otherwise communicate with us.

Content. We may collect other content and information you share through the Community when you submit information or content, such as by publishing a post and/or comment on our Platform, or when you otherwise interact with ScriptRunner Loop. Such Content might include Personal Data, at your discretion.

B. Personal Information That May Be Collected Automatically Through the Community

When you access or use ScriptRunner Loop, we may automatically collect information you provide to us, information about how you access and use the Platform and information about the device you use to access the Community, including:

Device Identifiers. Identifiers, such as your IP address, internet service provider, the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons and similar technologies we deploy on the Platform.

Internet or Other Electronic Network Activity Information. We may collect information about the devices and computers you use to access ScriptRunner Loop, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use our Platform, we may collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Community and other information about your internet activity (“Usage Information”), including the pages you visit, the links you click,  videos you watch, your location when you access or interact with our Platform, and other similar actions. We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Community and may record your mouse movements, scrolling, clicks and keystroke activity and other browsing, search or purchasing behavior. These tools may also record Usage Information you enter when you interact with the Community or engage in chat features through the Community.

Information From Cookies and Similar Technologies. We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics, may use these technologies to collect information about your online activities over time and across different services. 

For clarification purposes, Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Community.

For the avoidance of doubt, we would like to inform you that: 

• Circle, as platform provider, utilises some essential and non-essential Cookies in accordance with its own Cookie Policy available here; 

• The Adaptavist Group utilises Cookies across all its websites, as further detailed in the Adaptavist Privacy Policy available here. Additionally, information around how ScriptRunner Loop utilises essential and non-essential Cookies for its purposes specifically is provided via this Privacy Policy; 

• A detailed breakdown of the Cookies used by both Circle or TAG in relation to the ScriptRunner Loop platform is available here. 

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. You have the right to manage Cookies and customise Cookie preferences by interacting with the Cookie banner on the Platform. Please note that if you delete or choose not to accept Cookies from the Community, you may not be able to utilise the features of the Community to their fullest potential.

C. Personal Information Collected from Third Parties

Information from Third-Party Sources. When you interact with  members  of ScriptRunner Loop, we may collect from them any content or information you choose to share or provide. 

3. Personal Information Usage

We use the Personal Information we collect about you to:

• provide, maintain, and improve the Platform and to enhance and personalise your experience. This includes the creation of user account(s);

• process, complete, and maintain records on transactions (where applicable);

• moderate user content and behaviour while using the Platform, to ensure Community guidelines are followed. This shall include maintaining records of actions taken as part of the Platform moderation efforts; 

• send you technical notices, updates, security alerts, and support and administrative messages;

• respond to your comments, questions, and requests, and to provide customer service;

• communicate with you about products, services, offers, promotions, rewards, and events offered by ScriptRunner Loop, and provide news and information we think will be of interest to you;

• monitor and analyse trends, usage, effectiveness and activities in connection with the Community, including our offers, advertising, communications features, and customer service;

• meet our legal and regulatory obligations, including but not limited to the detection, investigation and prevention of fraud or other illegal activities and protect the integrity and security of ScriptRunner Loop and/or the rights of its members;

• facilitate contests and/or  promotions and process and deliver entries and rewards;

• where applicable, link or combine with Personal Information we get from the Platform, with Personal Information previously submitted to TAG or publicly available,  to help understand your needs and provide you with better service;

• maintain appropriate records for internal administrative purposes; and

• carry out any other purpose described to you at the time the Personal Information was collected, or as permitted by law.

4. Lawful Basis for Processing of Personal Data

The Processing of your Personal Data will fall into one of the following lawful basis categories: 

1. Consent: you have given clear consent for us to Process your Personal Data for a specific purpose; 

2. Contract: the Processing is necessary for a contract between you and us, or because you have asked us to take specific steps before entering into a contract; 

3. Legal obligation: the Processing is necessary for you or us to comply with the law;

4. Legitimate interests: Personal Data Processing is necessary for the purposes of our legitimate interests. 

5. Personal Information Disclosure

Affiliates within The Adaptavist Group. Employees of different corporate entities within The Adaptavist Group may need to access the information that you provide to us, for technical, commercial, compliance, security or other reasons, in accordance with this Privacy Policy.

Partners. We may disclose any information we receive to our partners, for any purpose described in this Privacy Policy.

Circle. The Platform is powered by a technology platform provided by CircleCo, Inc. (“Circle”). We may disclose your information to Circle in connection with the provision of the Community.

Service Providers and Vendors. We may disclose your information to other vendors, and service providers retained in connection with the provision of the Community.

Other Members of the Community. While the ScriptRunner Loop Platform is intended for ScriptRunner Users, please note that any activity published on the Platform can and will be seen publicly on the internet. Consequently,  by publishing posts, replying to comments, or otherwise participating in ScriptRunner Loop, the entirety of such information (including Personal Data if you have decided to include such data in your actions on the Platform) becomes public information. This implies that such information, including Personal Data, may be used by other members of the Community as well as the general public on the internet, by means including but not limited to sharing such information externally, creating a screenshot, or copying and pasting it. We cannot prevent further use of this information, and therefore strongly advise you to carefully consider what Personal Information you disclose on the Platform, which we recommend at all times should exclude sensitive Personal Information. 

Analytics Partners. We use analytics services to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. 

Legal and Law Enforcement. To the extent required or permitted by law, we may share information collected about you with law enforcement, governmental agencies, or authorised third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other ScriptRunner Loop member to legal liability or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

In Connection with a Change of Control. We may transfer or disclose your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

Consent. Where applicable, we may share your information with your consent or at your specific direction.

*A list of service providers or vendors, and analytics partners your Personal Data might be shared with or Processed by is included in Annex 1 – Third-Party Providers. 

6. Personal Data Retention Period

We will keep and Process your Personal Data only for as long as is necessary for the purposes for which it was collected, unless We have a legal obligation or legitimate interest to retain it for a longer period.

7. Children’s Privacy

The ScriptRunner Loop Platform is not intended for individuals under the age of 18. No one under the age of 18 is authorised to provide any Personal Information through the Community. We do not knowingly collect Personal Information from the Community from members in this age group. If we learn that we have collected or received Personal Information from a child under the age of 18, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 18, please contact us at the email address below.

8. Social Sharing Features

The Platform may offer social sharing features and other integrated tools, which let you share actions you take on the Platform with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and Processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

9. Third-Party Websites

The ScriptRunner Loop Platform may contain links to other websites, including our affiliated or co-branded websites and communities of The Adaptavist Group. Third-party websites and communities may also reference or link to ScriptRunner Loop. These other websites and communities may not be controlled by us. We encourage our members to read the privacy policies of every website, community, or mobile application that collects Personal Information. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites, communities, or mobile applications. Visiting these other websites is at your own risk.

10. Security

The Adaptavist Group implements appropriate technical and organisational measures to safeguard Personal Data Processed pursuant to this Privacy Policy. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

11. International Data Transfers

We collect information globally and may transfer, Process, and store your information outside of your country of residence, to wherever we, our affiliates or our third-party service providers operate for any of the purposes mentioned in section 4 above, as and when applicable. 

For your information, the Community is hosted in the United States (as it is powered by CircleCo). By consenting to this Privacy Policy, you acknowledge and agree that by using the Community from the EU, UK or other regions of the world with laws governing data collection that may differ from U.S. Law, you consent to the transfer of your Personal Information outside of those regions to the U.S. for storage and Processing. 

Whenever Personal Data of EU or UK residents is shared with affiliates or third-parties outside of the EEA or UK respectively, we ensure a similar degree of protection is afforded to it by the data importer by ensuring at least one of the following safeguards is implemented: 

A. In respect of UK Residents’ Personal Data:

• The data importer is based in a third country or a territory that offers an adequate level of protection of Personal Data, pursuant to an adequacy decision of the UK Government Secretary of State; 

• Appropriate safeguards are put in place to ensure that enforceable data subject rights and effective legal remedies for data subjects are available, and may consist of: 

  • a legally binding and enforceable instrument between public authorities or bodies; or

  • the implementation of the UK Data Transfer Agreement (or the UK Addendum, as applicable) as a valid transfer mechanism;

B. In respect of EU Residents’ Personal Data:

The data importer is based in a third country or a territory that offers an adequate level of protection of Personal Data, pursuant to an adequacy decision of the European Commission; 

• Appropriate safeguards are put in place to ensure that enforceable data subject rights and effective legal remedies for data subjects are available, and may consist of: 

  • a legally binding and enforceable instrument between public authorities or bodies; or

  • the implementation of the EU Standard Contractual Clauses as a valid transfer mechanism;

12. Your Choices

Account Information. You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to deactivate your Account, you may either (i) do so from your account settings or (ii)  email us at scriptrunnerhq@adaptavist.com to request we deactivate it on your behalf. Deactivating your account will not result in the deletion of your name, posts, comments or any other engagement within the Platform, but simply in the impossibility for other Community members to access your profile information.

Account Deletion. If you wish to permanently delete your account and any Personal Data and content associated with it, you can email us at  scriptrunnerhq@adaptavist.com  to request this. Opting for the permanent deletion of your account will result in the permanent deletion of your profile, as well as the entirety of your posts, comments or any other engagement within the Platform. 

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

13. Your Rights

Depending on your location and the specific applicable legislation, you, as a data subject, benefit from a number of rights in respect of your Personal Data that we hold and/or Process. 

A. If you are an EU or UK resident, you have the following rights:

• Right to be informed: as a data subject, you have the right to know what Personal Data we collect and Process. 

• Right to access: this includes your right to request information about your Personal Data Processed by us pursuant to this Privacy Policy; 

• Right to rectification: if you believe Personal Data we hold about you is inaccurate or incomplete, you can ask us to rectify that;

• Right to erasure: in some circumstances, you have the right to request that we delete any Personal Data we hold about you. This right is available to you unless further Processing is required for a) exercising the right of freedom of expression and information, b) reasons of public interest, c) the fulfilment of a legal obligation or d) the establishment, exercise or defence of a legal claim. 

• Right to restrict Processing: in some circumstances, you are entitled to ask us to suppress Processing of your Personal Data. This implies we will stop actively Processing your Personal Data but we do not have to delete it.

• Right to data portability: You have the right to receive your Personal Data that you have provided to us and we store in our systems, in a structured, commonly used and machine-readable format.

• Right to object: you have the right to object to us Processing your Personal Data if: a) the Processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority, b) for direct marketing purposes, and c) for purposes of scientific or historical research and statistics. In order to object, you must have grounds for doing so based on your particular situation. 

B. If you are a resident of California, you have the following rights:

• Right to know: you can request information about what Personal Information of yours we Process; 

• Right to delete: you can request that we delete the Personal Information we have collected or Processed under this Privacy Policy; 

• Right to opt-out: you can request that we stop selling your Personal Information. For clarification purposes, please note that we do not practice the selling of Personal Information Processed pursuant to this Privacy Policy. Notwithstanding, in compliance with CCPA requirements, please find the “Do not sell or share my personal information” button here; 

• Right to limit: you can request that we limit the use of your sensitive Personal Information. Please note that we do not intend to collect any sensitive Personal Information from you under this Privacy Policy, and that we further advise you refrain from sharing any sensitive Personal Information on the Platform. 

• Right to non-discrimination: we acknowledge your right to be treated in a non-discriminatory manner while you exercise your rights under CCPA. 

14. Contact Us

If you have any questions, comments or concerns about our Privacy Policy, or if you want to exercise your rights as detailed herein, you may email us at scriptrunnerhq@adaptavist.com. Additionally, if you have any questions, comments or concerns about our Privacy Policy feel free to send correspondence to the following address:

ScriptRunner Loop 

With its office at: 

Adaptavist, 25 Wilton Road, Victoria, London, United Kingdom, SW1V 1LW.

Annex 1 — Third-party Providers

Marketing and Analytics Cookies

• Segment — see provider’s privacy terms here.

• Google Analytics (GA4) — see provider’s privacy terms here.

CRM Database

• HubSpot — see provider’s privacy terms here.

Data Integration and Storage

• AWS (S3) — see provider’s privacy terms here.

Moderation Log

• SeaTable — see provider’s privacy terms here.

Platform hosting

• CircleCo — see provider’s privacy terms here.

Internal Operations Communications

• Slack — see provider’s privacy terms here.

Cookie and Tracker Consent Management Software

• TrustArc — see provider’s privacy terms here.