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Legal · Subscribers

Subscriber Privacy Notice

Effective date: 2 July 2026 · Version 1.0 · Scout & Scout Team

This notice explains what personal data we process when you use the Scout or Scout Team product, why, on what legal basis, who we share it with, and your rights under the EU General Data Protection Regulation (GDPR) and Finnish data-protection law. It is separate from, and complementary to, our website Privacy Policy, which covers personal data we collect through groundworksai.com (the waitlist, bookings, the newsletter, and site logs).

1. Who we are (data controller)

Groundworks Marketing AI Oy (Business ID / Y-tunnus 3625461-9), Finland, trading as Groundworks AI, is the controller for the personal data described in this notice. Registered address Toinen Linja 3 B 24, 00530 Helsinki, Finland. For privacy questions or to exercise your rights, contact us at privacy@groundworksai.com.

2. Scope and roles

This notice covers personal data processed inside the Scout/Scout Team product for subscribers. We hold two different roles depending on the data:

  • We are the controller for your account and billing data — the data that identifies you as our customer and lets us run your subscription (see §1, §3, and the legal bases in §4).
  • We are your processor for personal data contained in the content you generate, your inputs, and your connected audiences/integrations (for example, contacts you address in outreach). For that data you are the controller and we act on your instructions. The Data Processing Agreement governs that relationship — not this notice.

3. What we collect

CategoryExamplesSource
Account & billingName, business name, email, login credentials, plan, payment details (held by Stripe — we do not store full card numbers)You
Intake dataThe Day-0 intake form (company context, ICP, offer and positioning, voice, growth motion, cadence preferences)You
Website-scrape dataBrand tokens (logo, colours, fonts), primary CTA, and image assets crawled from your own website, which you confirm or edit at intakeFirst-party crawl of your site, with your instruction
In-platform signalsYour review/approval history and patterns, content-fuel responses, self-reported outcomesYour use of the service
Integration reads (Scout Team)Newsletter performance, social engagement metrics, and workspace context from the accounts you connectConnected integrations, with your authorisation
Audience/recipient data in your contentPersonal data of people you address in generated content/outreachYou (you are controller — see the DPA)
Technical & usageIP address, device/browser data, log and usage data within the productAutomatically

We do not intentionally collect special-category personal data, and you should not submit it through the service.

4. Why we use it, and our legal basis

PurposeLegal basis (GDPR Art. 6)
Provide, operate, and support the service; generate and deliver your contentPerformance of a contract (Art. 6(1)(b))
Process payments and manage subscriptionsContract (Art. 6(1)(b)); legal obligation for tax/accounting (Art. 6(1)(c))
Improve and secure the service; prevent abuseLegitimate interests (Art. 6(1)(f)) — our interest in keeping the service reliable, secure, and free of misuse, and in fixing and improving it, balanced against your rights
Connect and read the integrations you enable (Scout Team)Contract (Art. 6(1)(b)) and your authorisation
Product/service communications to you (e.g. run notifications)Legitimate interests (Art. 6(1)(f)) — our interest in keeping an active subscriber informed about the service they pay for
Comply with legal obligationsLegal obligation (Art. 6(1)(c))

We do not sell your personal data.

4a. Do you have to provide this data?

(Art. 13(2)(e) GDPR.) Providing your account, billing, and intake data is a contractual requirement — we need it to deliver the subscription, and without it we cannot provide the service (e.g. we cannot bill you, set up your account, or generate content fitted to your business). Providing data through the integrations you choose to connect (Scout Team) is optional, but the related features will not work if you do not.

Automated decision-making. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing (Art. 22 GDPR). Content is generated using AI, but every item is surfaced to you for review and approval in The Review before it is used — a human (you) is always in the loop.

5. AI processing (Anthropic / Claude)

To generate your content, we send relevant inputs and signals to Anthropic's Claude via Anthropic's commercial API. Anthropic processes this data as our sub-processor to return generated content. Anthropic does not use commercial-API inputs or outputs to train its models by default, and deletes them within 30 days of processing (longer only where required for safety review or by law). We are in the process of arranging Zero-Data-Retention (ZDR) with Anthropic for our production models; if and once ZDR is in place, Anthropic retains no inputs or outputs at rest beyond returning your content. Until then, the 30-day default above applies. You never provide an Anthropic API key; we operate the service under a single commercial account.

6. Sub-processors

We use the following third parties to provide the service. Each processes personal data only as needed to perform its function, under contract. The Data Processing Agreement (Annex III) carries the authoritative list.

Sub-processorPurposeApplies to
AnthropicAI content generation (Claude)Scout & Scout Team
Fly.io (EU region)Product application hosting / data storageScout & Scout Team
StripePayment processingScout & Scout Team
NotionWorkspace-context read (the source you nominate)Scout Team
bundle.socialSocial publishing; holds your connected-account tokensScout Team
BeehiivNewsletter publishingScout Team

Website-only providers (e.g. our website host and form/scheduling tools) are listed in the website Privacy Policy, not here. Stripe processes your account and billing data, for which we are the controller — it is a controller-side processor for that data. For Scout Team publishing, the aggregator holds the access tokens for the social accounts you connect (encrypted at rest); we store only a reference to your connected account, not the tokens themselves.

7. Where your data is processed

We host and process data in the EU/EEA (our application runs in an EU region — Fly.io EU, see §6). Some sub-processors process data outside the EEA, principally in the United States (e.g. Anthropic, Stripe). Where they do, the transfer is protected by an appropriate safeguard under Chapter V GDPR — the EU–US Data Privacy Framework where the provider is certified, and/or the European Commission's Standard Contractual Clauses. You can obtain a copy of the relevant safeguard, or details of the mechanism that applies to a specific sub-processor, by contacting privacy@groundworksai.com.

8. How long we keep it

We keep personal data for as long as needed for the purposes above and to meet legal obligations. Specifically:

  • While your subscription is active, we keep your data for the life of the subscription.
  • When your subscription is paused or ends, your settings and signal pool are retained for 90 days so you can resume with continuity. On cancellation we provide an export of your content within 48 hours.
  • After that, your data is deleted within 30 days (of cancellation, or of the 90-day pause window expiring without resume), including from backups within one backup cycle.
  • Billing and accounting records we are legally required to keep are retained for the statutory period under the Finnish Accounting Act (Kirjanpitolaki 1336/1997, ch. 2 §10): accounting books and financial statements for at least 10 years, and vouchers and related business correspondence for at least 6 years, in each case from the end of the financial year — after which they are deleted. This applies only to those records; it does not extend to your intake, content, or signal data.

9. Your rights

Under the GDPR you have the right to: access your data; have it corrected; have it erased; restrict or object to processing; data portability; and — where we rely on your consent — withdraw that consent at any time, without affecting the lawfulness of processing before withdrawal. To exercise any right, contact privacy@groundworksai.com. We provide an in-product export to support access/portability. We respond without undue delay and within one month of your request (extendable by two further months for complex or numerous requests, in which case we will tell you), per Art. 12(3) GDPR.

You also have the right to lodge a complaint with the Finnish supervisory authority, the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto) — tietosuoja.fi.

10. Security

We apply appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, EU-region hosting, and sub-processors who maintain recognised security standards. No system is perfectly secure; we will notify you and the supervisory authority of a personal-data breach where required by law.

11. Cookies and in-product storage

The Scout/Scout Team product uses only the essential cookies/local storage needed to sign you in and run the application (e.g. session management). It does not use advertising or tracking cookies. Cookies on the public website are covered by the website Privacy Policy.

12. Children

The service is for business use by adults. It is not directed at children, and we do not knowingly collect data from anyone under 18.

13. Changes

We may update this notice. The version and date at the top show when it last changed, and each version is tagged material or minor:

  • Material change — for example adding a sub-processor or a new purpose or legal basis for processing your data — we will notify you and ask you to actively accept the updated notice before you continue using the service (the same tiered re-acceptance that applies to the Terms of Service, clause 16). Until you accept, new content runs are paused and your data is retained.
  • Minor change — clarifications or non-material updates — we will post the updated version and notify you in-product or by email; continued use is acceptance.

14. Contact

Privacy questions and rights requests: privacy@groundworksai.com. Supervisory authority: Office of the Data Protection Ombudsman, Finland (tietosuoja.fi).

Effective 2 July 2026 · Version 1.0 · Groundworks AI is the trading name of Groundworks Marketing AI Oy · groundworksai.com

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