Home Privacy Policy (DRAFT)

Privacy Policy (DRAFT)

1. Purpose of This Privacy Policy

Alcohol Monitoring Systems, Inc., Alcohol Monitoring Systems, Ltd., 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.

It is important that you read this privacy policy carefully together with any other fair processing notice or privacy policies we may provide on occasions when we collect or process personal data about you, so you are fully aware how and why we are using your data. This privacy policy supplements these other policies and does not replace them.

This privacy policy contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

2. Who We Are

To contact us, please use the following information:

United States United Kingdom/European Union
  • Email address: info@scramsystems.com
  • Mailing address: 1241 West Mineral Ave, Littleton, CO 80120
  • Telephone number: 303-989-8900
  • Email address: info@scramsystems.com
  • Postal address: Level 18, 40 Bank Street (HQ3), Canary Wharf, London E14 5NR United Kingdom
  • Telephone number: +44 (0) 20 3059 7797

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 offences 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.

Purpose/Activity Type of Data The Lawful Basis For Processing, Including Legitimate Interest
To register you as a new or potential customer Identity; Contact 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 Technical; Usage 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 Data Subjects, 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, except:

Such transfer of your data will always be subject to our physical, technical, and organizational measures detailed in paragraph 10.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Alcohol Monitoring Systems remains liable.

If you do not receive a timely acknowledgment of any complaint you raise, or if your complaint is not satisfactorily addressed, you can also submit your complaint to PrivacyTrust, an independent third party. Visit https://www.privacytrust.com/drs/alcoholmonitoringsystemsinc to file a complaint. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield panel, a binding arbitration mechanism.

8. Cookies

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:

Cookie Name Category Description Additional Information
Pardot Pi_opt_in Analytical This cookie is set with a true or false value when the visitor opts in or out of tracking.  
Pardot visitor cookie Analytical 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 Marketing This cookie is set to learn how users have interacted with our advertising served to them on Twitter. See Conversion Tracking for Websites for more information.
LinkedIn Insight Tag Marketing 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 data is encrypted. The LinkedIn browser cookie is stored until you manually delete it or when the cookie expires (there’s a rolling six-month expiration from the last time the visitor’s browser loaded the Insight Tag). For more information about the LinkedIn Insight Tag, view their terms of service and cookie policy.
Cb-enabled Necessary This cookie is associated with the cookie alert notice on our site. It is used to record when you have dismissed the notice to prevent it re-appearing on return visits.  
_ga Analytical 1This 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
_gid Analytical This cookie stores and update a unique value for each page visited.  
_gat Analytical This cookie limits the collection of data on high traffic sites. Expires after 10 minutes
wordpress_test_cookie Necessary This cookie tests whether or not your browser has cookies enabled. For www.sobering-up.com only.
wp-settings-{time}-[UID] Necessary This is used to customize your view of our site. For www.sobering-up.com only.

If you are a visitor from the European Union, you will have the option to set your browser to refuse some or all browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our site may become inaccessible or may not function properly.

9. Our Sites and Third-Party Websites

Our sites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy policies. When you leave our sites, we recommend that you read the privacy policy of every website you visit and every plug-in or application you use.

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 info@scramsystems.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 using the contact details above. Please notify us with any changes to your personal data at any time.

14. Changes to Our Privacy Policy

Any changes we may make to this privacy policy in the future will be posted on our site, https://ww.scramsystems.com/privacy-policy. Please check back regularly to keep informed of updates or changes to this privacy policy.

15. Additional Information for Clients Monitored With SCRAM Systems Products

We also collect information under the direction of its customers and has no direct relationship with the clients whose personal data it processes.


We collect information for our customers. If you are a 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 the customer that you interact with directly. If you are a customer and would like to update your account, please contact us at info@scramsystems.com.

Service Provider, Sub-Processors/Onward Transfer

We may transfer personal information to companies that help us 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 clients whose personal data it processes. An individual who seeks access to, or who seeks to correct, amend, or delete inaccurate data should direct his query to the customer (the data controller). If our customer requests us to remove the data, we will respond to their request within 30 business days.

Data Retention

We will retain personal data we process on behalf of our customers for as long as needed to provide services to our customer. We will also retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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