Privacy Policy

    Last updated: March 18, 2026

    1. Controller

    SCRTY B.V., a company incorporated under Dutch law, with its registered office in the Netherlands ("SCRTY", "we", "us"), is the data controller for the processing of personal data described in this Privacy Policy. Anzen® is a product of SCRTY B.V.

    2. What Data We Collect

    When you use Anzen, we may collect the following categories of personal data:

    • Account data — name, email address, organisation name, and hashed password.
    • Usage data — IP address, browser type, pages visited, and timestamps for security and service improvement.
    • Service data — tickets, issues, configuration items, and other records you create within your workspace. This data is owned by your organisation.
    • Billing data — payment method details processed via our payment provider (Mollie B.V., a Dutch payment processor).

    3. Legal Basis for Processing

    We process your personal data on the following legal grounds under the GDPR:

    • Contract performance (Art. 6(1)(b)) — to provide the Anzen platform and support services.
    • Legitimate interest (Art. 6(1)(f)) — to improve our services, ensure security, and prevent fraud.
    • Legal obligation (Art. 6(1)(c)) — to comply with applicable laws, including tax and accounting requirements.
    • Consent (Art. 6(1)(a)) — for optional communications such as product updates. You may withdraw consent at any time.

    4. Data Hosting and Sovereignty

    All personal data and service data is stored and processed exclusively within the European Union on infrastructure owned and operated by SCRTY B.V. We do not use US-based cloud providers (such as AWS, Microsoft Azure, or Google Cloud) for the storage or processing of your data.

    Your data never leaves the EU. We maintain our own infrastructure in European data centres to ensure full compliance with GDPR data residency requirements and to eliminate foreign jurisdiction risks.

    5. Data Sharing

    We do not sell your personal data. We may share data with the following categories of recipients:

    • Payment processor — Mollie B.V. (Netherlands) for billing transactions.
    • Email delivery — Scaleway SAS (France) for transactional emails.
    • Legal authorities — when required by Dutch or EU law.

    All sub-processors are EU-based and bound by data processing agreements.

    6. Data Retention

    We retain your personal data for as long as your account is active or as needed to provide our services. Upon account deletion, we remove your personal data within 30 days, except where retention is required by law (e.g. invoicing records for 7 years under Dutch fiscal law). Service data within your workspace is deleted when the workspace is deprovisioned.

    7. Your Rights

    Under the GDPR, you have the following rights regarding your personal data:

    • Access — request a copy of the data we hold about you.
    • Rectification — correct inaccurate or incomplete data.
    • Erasure — request deletion of your personal data ("right to be forgotten").
    • Restriction — restrict processing in certain circumstances.
    • Portability — receive your data in a structured, machine-readable format.
    • Objection — object to processing based on legitimate interest.

    To exercise any of these rights, contact us at privacy@scrty.nl. We will respond within 30 days.

    8. Security

    We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit (TLS), fully isolated tenant workspaces, role-based access control, and full audit logging of all data access and modifications.

    9. Cookies

    Anzen uses only strictly necessary cookies for authentication and session management. We do not use tracking cookies, advertising cookies, or third-party analytics. No cookie consent banner is required as we only use essential cookies (per GDPR recital 30 and ePrivacy Directive Art. 5(3) exemption).

    10. Changes to This Policy

    We may update this Privacy Policy from time to time. Material changes will be communicated via email or a notice within the platform. Continued use of Anzen after changes constitutes acceptance of the revised policy.

    11. Contact & Complaints

    For privacy-related questions or to exercise your rights, contact us at privacy@scrty.nl.

    If you believe we have not adequately addressed your concern, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.