(processing of personal data)
Last updated: October 28, 2025
1. Who we are and what this Policy covers
1.1. This Privacy Policy (the “Policy”) describes what data is processed when you use the Scrugio service available at:
(together, the “Service”).
1.2. Access to the Service is provided by scrugio.com (“we”, “us”).
1.3. By using the Service (including requesting access, registering, or signing in), you confirm that you have read this Policy and agree to it.
1.4. This Policy is drafted with regard to applicable data protection laws (including, where relevant, GDPR, CCPA/CPRA, and similar laws).
1.5. The Service is in limited access / testing mode. Certain features may be unavailable or changed without prior notice.
2. What data we collect
We intentionally aim to collect the minimum amount of personal data.
2.1. Email
- Your email address.
Why:
- to create or activate access to the Service,
- to send sign-in / recovery links,
- to notify you about the end of a trial period, important changes to the Service or access terms.
This is the only required personal identifier you provide to us.
We do not request your first/last name, phone number, job title, company, etc.
2.2. Data you enter into models
The Service is intended for financial modeling (sales, headcount/compensation, purchasing, budgets, cash flow). That means you may enter any business data, including:
- revenue and sales forecasts,
- sales funnel, average check, conversion, LTV,
- cost and purchasing data,
- team plans (headcount, salaries, payroll/comp, hiring/firing, etc.),
- budgets and plan/actuals.
None of these fields are required by us. You decide what to upload.
Important: If you enter personal data of third parties (e.g., the real salary of a specific employee by name), you are responsible for having the legal right to do so. In effect, you act as the personal data operator with respect to your employees.
2.3. Technical data
When accessing the Service, the following may be processed automatically:
- IP address used for connection,
- browser and device type information,
- cookies or a session token (so you aren’t logged out immediately after signing in).
Why:
- authorization,
- protection against unauthorized access,
- service stability.
3. How we use data
We use data only for the following purposes:
3.1. Access to the Service
- user registration/activation, sign-in, access recovery.
3.2. Product operation
- storing and displaying the models you enter (sales, team, purchasing, budgets, etc.),
- fixing technical issues and improving stability.
3.3. Critical communications
- notices about trial expiration, changes to access plans, changes to Terms of Use, changes in Service operation, and important incidents/outages.
We do not use your email for third-party “sales/marketing blasts” and do not share your email with third parties for marketing purposes.
4. Cookies and local storage
4.1. We may use cookies, localStorage, and similar mechanisms to:
- keep your session active so you don’t have to log in each time,
- remember interface settings,
- show the correct plan / trial status.
4.2. If you disable cookies on your device, sign-in and account functionality may become unavailable or partially incorrect.
5. Sharing data with third parties
5.1. Lawful requests of competent public authorities — Only if required by applicable law and properly documented.
Hosting and infrastructure providers
(servers, database storage, logging systems).
They may technically have access to your email and the data you upload to the model. These vendors are required to ensure confidentiality.
Payment services
(if you pay for access after a trial).
They receive data necessary to process the payment. We do not store full bank card details.
Lawful requests of RF government authorities
Only if directly required by applicable RF law and properly documented.
5.2. We do not sell your personal data.
5.3. We do not use your models (e.g., payroll sheets or hiring plans) to advertise to other clients.
6. Where data is stored and for how long
6.1. We may store and process data in the EEA, the United States, and other countries where we or our service providers operate.
6.2. In operating the Service, we may use backup and auxiliary technical capacities (including the app.scrugio.com domain) that may be located outside your country. Such processing may include backups, notifications delivery, stability monitoring, and incident analytics. Where required, we use appropriate safeguards for international transfers (e.g., Standard Contractual Clauses).
6.3. Retention:
- email address — while you have access/an account in the Service and for a reasonable period after deactivation (for dispute resolution and record-keeping);
- technical event logs — for the period necessary for security and debugging;
- data you entered into models (sales, team, purchasing, budgets, etc.) — while the account is active or until you delete it.
If you request account deletion, we delete (or block) personal data associated with it, except where retention is required by law (e.g., payment data, accounting records). In that case, such data is moved to restricted processing and is not used in operational activities.
7. Your rights
Under applicable law, you may:
7.1. Request access to your personal data
I.e., learn what data we have about you (primarily your email and related technical records).
7.2. Request correction
For example, change your contact email.
7.3. Request deletion
You may request deletion of your account and related data.
Exception — data that must be retained by law for a defined period (e.g., payment-related).
7.4. Withdraw consent to personal data processing
If you withdraw consent, we stop processing your personal data. This almost always means your access to the Service will be terminated (because we cannot authorize you without an email).
8. How to contact us about data
For any data questions, including:
- obtaining a copy of the data we hold,
- deleting an account,
- changing your email,
- restricting processing,
contact: 📧 business@scrugio.com
Please include the email that was used to access the Service so we can identify the account.
9. Important notes about employee data
9.1. The Service allows modeling team structure, salaries, payroll (FOT), hiring, terminations, headcount plans, etc.
9.2. We do not require you to enter real employee full names. You can work in aggregate (e.g., “Sales Manager ×3 at 120k”) instead of specific individuals.
9.3. If you enter real personal data of third parties (e.g., employees’ surnames and their salaries), you confirm that you are authorized to do so under your internal policies and applicable data protection law.
10. Updates to this Policy
10.1. We may update this Policy. The current version is published at https://scrugio.com/privacy and may change without separate personal notice.
10.2. Continued use of the Service after a new version is published constitutes your acceptance of the updated Policy.
10.3. If you do not agree with the Policy, you must stop using the Service and may request account deletion.
11. If you’re “just browsing”
11.1. If you simply open scrugio.com for information and do not register, the only data that may be processed automatically are technical connection data (IP, cookies, browser information) for displaying the site and protecting against spam/abuse.
11.2. You can block cookies in your browser settings. In this case, some parts of the site may display or function inconsistently.