The following statement was last updated on May 25, 2021
- Who We Are
- The Data That We Collect
- How Your Personal Data is Collected
- How We Use Your Personal Data
- Who Do We Share Your Personal Data With
- EU/UK Data Subjects and International Transfers
- Our Sites and Third-Party Websites
- Data Security
- How Long Will You Use My Personal Data?
- Accessing Your Personal Data and Your Rights
- Changes to Your Personal Data
- Additional Information for Clients Monitored with SCRAM Systems Products
Alcohol Monitoring Systems, Inc. and SCRAM Systems (“we“, “us” or “our”) provide these websites, www.scramsystems.com, www.jailovercrowding.com, and www.sobering-up.com (our “sites”). We are committed to protecting and respecting your privacy. This privacy notice tells you how we look after your personal data when you visit our sites (regardless of where you visit from) and about your privacy rights and how the law protects you and aims to give you information on how we collect and process your personal data through your use of our sites, including any data you may provide on our sites when you contact us.
Our sites are not intended for children and we do not knowingly collect data relating to children.
2. Who We Are
To contact us, please use the following information:
|United Kingdom/European Union
|Email address: firstname.lastname@example.org
Mailing address: 1241 West Mineral Ave, Littleton, CO 80120
Telephone number: 303-989-8900
|Email address: email@example.com
Postal address: Level 1, Devonshire House, One Mayfair Place, London W1J 8AJ United Kingdom
Telephone number: +44 (0) 207 268 4852
For the purpose of data protection laws in the UK, we are the controller of any personal data that we collect and process in connection with your use of our sites.
You have the right to complain at any time to the Information Commissioner’s Office (ICO), which is the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance.
3. The Data That We Collect About You
Personal data means any information about a person from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
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.
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.
4. How Your Personal Data is Collected
We collect your personal data in different ways, including:
- 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.
- Automated technologies. When you interact with our sites, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites using our cookies. Please see below for more information about cookies.
- 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 Twitter Conversion Tracker, and the LinkedIn Insight Tag;
- contact information about you from business partners, events, conferences, or industry tradeshows; and
- other individuals under our “refer a client” form.
5. How We Use Your Personal Data
We will only use your personal data when the law allows us to do so. Our most common uses of your personal data will be:
- in order for us to perform a contract we are about to make or have made with you (or to take steps at your request before entering such a contract);
- if it is necessary for our legitimate interests and your interests and rights do not override those interests; and/or
- in order for us to comply with a legal or regulatory obligation.
The table below sets out all the ways in which we plan to use your personal data, which of the legal bases we rely on to do so and, where relevant, what the legitimate business interests are. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.
|Type of Data
|The Lawful Basis For Processing, Including Legitimate Interest
|To register you as a new or potential customer
|Performing a contract that we have with you
|To manage our relationship with you, including notifying you of changes in our terms or privacy notice
|Identity; Contact; Marketing and communications
|Performing a contract that we have with you
Complying with our legal obligations
Our legitimate business interests (keeping our records up-to-date, studying how customers use our products/services)
|To administer and protect our business and our sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting data)
|Identity; Contact; Technical
|Our legitimate business interests (running our business, providing admin and IT services, network security, preventing fraud, for a business reorganization or group restructuring)
Complying with our legal obligations
|To use data analytics to improve our site, products, services, marketing, customer relationships, and experiences
|Our legitimate interests (keeping our site updated and relevant, developing our business and informing our marketing strategy
|To suggest products and/or services which may be of interest to you
|Identity; Contact; Technical; Usage; Marketing and communications
|Our legitimate interests (developing our products/services, growing our business)
Your consent, which you can withdraw at any time via the link in the email, or by contacting us using the details above
You may receive marketing communications from us if you have requested such information from us. You may also receive marketing communications from us if you have purchased similar products or services from us or if you provided us with your details.
You can ask us, and/or any third party, to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you.
If you opt-out of receiving any marketing messages, this will not apply to personal data provided to us for other purposes, for example, as a result of your purchase of a product or service, warranty registration or other transaction.
6. Who Do We Share Your Personal Data With
- third parties within our group (whether acting as joint controllers and/or processors), who are based in the United States, the United Kingdom, Australia, or New Zealand and provide support, marketing, and administration services and reporting;
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency;
- in the event that we sell any part of our business, in which case we may disclose your personal data to the prospective buyer of that part of our business to the extent that such disclosure is directly relevant to the sale; and
- professional advisers (acting as processors or joint controllers), including lawyers, accountants, auditors, bankers, insurers, in each case based in the United States and/or the United Kingdom who provide legal, accountancy, audit, banking, insurance or consultancy, or other services to us and our group companies;
7. For EU/UK Data Subjects and International Transfers
Many of the third parties with whom we work are based outside both the United Kingdom (UK) and the European Union (EU), so their processing of personal data may involve a transfer of this data outside both the UK and the EU. When we use cloud-based platforms to store personal data, this may involve the use of geographically distributed data centers including data centers outside both the UK and the EU. If we transfer your information to third-party companies (e.g. analytics or web hosting vendors), we will ensure they maintain the same level of security as us. You have the right to request copies of the transfer mechanisms that apply to your personal data by contacting us using the details above. We will not transfer your personal data outside the EU or UK, except:
- to a company that has agreed to follow the same rules when processing your personal data;
- where your personal data benefits from the same contractual protections as it would in the EU or the UK;
- where the transfer is necessary to perform a contract between us; or
- with your explicit consent.
Such transfer of your data will always be subject to our physical, technical, and organizational measures detailed in paragraph 10.
You have the ability to limit the transfer of and/or delete your personal information. If you would like to request the deletion of your personally identifiable information or request that it be returned to you, please contact us at firstname.lastname@example.org.
A cookie is a small file, placed on a computer or mobile device (“Device”) that uniquely identifies your browser or Device when you visit a website. Cookies collect information to help identify you, your Device, your use of the website and/or your general internet usage.
We use the following categories of cookies:
- Necessary cookies: Some cookies are required to provide core functionality. Our websites won’t function properly without these cookies and they are enabled by default.
- Analytical cookies: These cookies allow us to recognize and count the number of visitors to our site and to see how visitors move around our site. This helps us to improve the way our site works, for example by ensuring that visitors can easily find what they are looking for.
- Marketing cookies. These are cookies that are placed by third party service partners, including advertising partners, to improve the relevance of the information we present on our site to our users. The information collected by these cookies can be shared with other organizations outside our group of companies. We have no control over these third-party cookies.
More information about the individual cookies we use and the purposes for which we use them is set out in the table below:
|This cookie is set with a true or false value when the visitor opts in or out of tracking.
|Pardot visitor cookie
|This cookie is composed of a unique visitor ID and the unique identifier for your account. For example, the cookie name “visitor_id12345” stores the visitor value “1010101010”, and “12345” is the account identifier. This cookie is set for visitors by the Pardot tracking code.
|Twitter Conversion Tracker
|This cookie is set to learn how users have interacted with our advertising served to them on Twitter.
|See Conversion Tracking for Web
sites for more information.
|LinkedIn Insight Tag
|This cookie is set for in-depth advertising campaign reporting and to help us view insights about our website visitors. The tag tracks conversions, retargets, website visitors, and provides additional insights about members interacting with our LinkedIn advertisements and boosted posts.
|This cookie will be set to true if the user originates in a locale that is under GDPR compliance laws, or if the user selects a location from the nav menu that requires GDPR compliance. It will be set to false if GDPR compliance is not required.
|This is set to either true or false.
|This cookie is associated with the cookie alert notice on our site. It is used to record if you have accepted cookies on the site.
|This is set to either true or false.
|This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session, and campaign data for our site’s analytics reports.
|Expires after 2 years.
|This cookie stores and update a unique value for each page visited.
|This cookie limits the collection of data on high traffic sites.
|Expires after 10 minutes.
|This cookie tests whether or not your browser has cookies enabled.
|This is used to customize your view of our site.
|This cookie is used to set an international visitor’s main menu preference controlled by the country drop down in the utility navigation.
|This is a performance cookie for efficiently loading resources. The value is always 1.
|More information: addtoany.com
|This cookie is used for security.
|More information: addtoany.com
9. Our Sites and Third-Party Websites
10. Data Security
We have appropriate physical, technical and organizational security measures in place to safeguard your personal data, and protect it from being accidentally or unlawfully destroyed, lost or altered, or disclosed or accessed in any unlawful way. We limit access to your personal data to those of our employees, agents, contractors and other third parties who have a genuine business need to know it, and those processing your information will do so only in an authorized manner.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We store your personal data in line with legal, regulatory, financial, and good-practice requirements. If you would like to find out more about how long we store your data for, please get in touch using the contact details above.
11. How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of complying with any legal, accounting, and/or reporting obligations.
In some circumstances, you can ask us to delete your personal data (see below).
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
12. Accessing Your Personal Data and Your Rights
As a result of us collecting and processing your personal data, you may have the following legal rights:
- to access personal data held about you;
- to request us to make any changes to your personal data if it is inaccurate or incomplete;
- to request your personal data is deleted where we do not have a compelling reason to continue to process such data in certain circumstances;
- to receive your personal data provided to us as a controller in a structured, commonly used and machine-readable format where our processing of your personal data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
- to object to, or restrict, our processing of your personal data in certain circumstances;
- if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
- if we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection; and
- to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you;
We commit to resolve questions and complaints about your privacy and our collection or processing of your information. If you believe that we are not complying with the terms of this policy or legal requirements, you should first contact us at the applicable address above, or by email at email@example.com. We will investigate and will do our best to internally resolve any complaints and disputes you bring to our attention regarding the use and disclosure of your information.
To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us using the contact details above.
13. Contacting Us and Changes to Your Personal Data
If you have any questions, comments, or requests about this privacy notice or your personal data, please contact us at firstname.lastname@example.org. Please notify us of any changes to your personal data at any time.
15. Additional Information for Clients Monitored with SCRAM Systems Products
SCRAM Systems conducts business directly with government agencies, courts, and authorized service partners (customers) who provide services to individuals that are required to be monitored under the conditions of a court order or other circumstance (monitoring clients).
We store information under the direction of our customers and have no direct relationship with monitoring clients whose personal data is processed.
If you are a monitoring client of one of our customers and would no longer like to be contacted by one or our customers that use our service, please contact us at email@example.com and we will forward your request to the appropriate customer to handle your request. To ensure the request is processed in a timely manner, SCRAM Systems will track and follow up with the customer as needed.
Service Provider, Sub-Processors/Onward Transfer
We may transfer personal information to customers that provide our service. Transfers to subsequent third parties are covered by the provisions in this policy regarding notice and choice and the service agreements with our customers.
Access to Data Controlled by Our Customers
We have no direct relationship with the monitoring clients whose personal data it processes. A monitoring client who seeks access to, or who seeks to correct, amend, or delete inaccurate data may direct his query to the customer (the data controller) or by submitting a request to firstname.lastname@example.org so we may forward the request to the appropriate customer.
We will retain personal data we process on behalf of our customers for as long as needed to provide services to our customers. We will also retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. As a monitoring client, if you would like to request the deletion of your personally identifiable information or request that it be returned to you, please contact SCRAM Systems at email@example.com and we will forward your request to the appropriate customer for removal. To ensure the request is processed in a timely manner, SCRAM Systems will track and follow up with the customer as needed.
SMS Text Opt In/Out Service Information
Monitoring clients have the option to sign up for automated SMS Text reminders as part of their monitoring service. When an individual opts into the service, we will send an SMS message to confirm registration.
Monitoring clients can cancel the SMS Text service at any time. Text “STOP”. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time, and we will start sending SMS messages to you again.
If at any time you forget what keywords are supported, just text “HELP”. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe.
We are able to deliver messages to the following mobile phone carriers:
Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile.
Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless).
Please note: Carriers are not liable for delayed or undelivered messages.
As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive messages as agreed to in the Participant Agreement. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. For all questions about the services provided by this short code, you can send an email to firstname.lastname@example.org.