By clicking “Accept All Cookies”, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. View our Privacy Policy for more information.

Website Privacy Policy

Your privacy is very important to us. In this document we provide you with information regarding the data we collect, how and why we collect it, and how we store and secure it.

1. Contact information

Customers and users of Pasabi, T/As Cunning Blade Ltd, may contact us via the information provided below.

We are registered in Scotland under registration number SC464610

Argyle House
3 Lady Lawson St,
Tel: (+44) 208 059 5500

Data Protection Officer
Martin Spinks

2. The information we collect

When using our website, app and/or services we collect the following information.
If you sign up to download resources, the following data is processed:

  • Your name
  • Your company name
  • Your email address
  • Your IP-address (anonymised)
  • Cookie preferences

If you visit our website, the following end user data is processed:

  • Your IP-address (anonymised)
  • The date and time of the consent
  • User agent of the End User’s browser and operating system
  • The URL from which the consent was submitted
  • An anonymous, random and encrypted key value
  • The End User’s consent state, serving as proof of consent

If you visit our website, the following system generated data is processed:

  • The type of your browser
  • The operating system that you use
  • The internet service provider
  • User device data

We specifically do not aim our services and products at persons under the age of sixteen (16). If personal data regarding such persons is discovered in our systems the data will be deleted without undue delay.

3. The purposes for which we process information

The information we process can be used for one or multiple of the following purposes:

  • Sending you newsletters

If you sign up for our newsletter we need your personal details to send you the newsletter and enable you to unsubscribe.

  • Market research
    • Pseudonymised, anonymised, and aggregated data collected from website visitors to help us improve our services.

4. Legal basis for processing

We always process your personal data with the utmost care. In this section the different legal bases we use are set out.
We always process your data on the basis of the consent you give us to do so. We could also process your data if it is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract. These legal bases are set out in article 6(1)(a) & (b) of the GDPR.

In order to enter into a contract regarding the purchase of one of our services, you must provide us with the required information. If you do not provide the required information it is not possible for us to deliver our services.

In some cases we are legally obliged to process your data, article 6(1)(c) GDPR. In that case, we will alway inform you of this processing, unless a legal obligation prevents us from doing so.

5. How we protect your data

We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

The following personal data will be stored by us in encrypted form: your name and contact information.

Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

6. How we use cookies

For information on our use of cookies, we refer you to our Cookie Policy.

7. Third parties

We may release your information when we believe release is appropriate to comply with the law, enforce our policies, or protect our and/or others’ rights, property, or safety. Furthermore, non-identifiable information may be provided to other parties for marketing, advertising, or other purposes.

We will not disclose personal data to law enforcement or other supervisory authorities, unless our customers instruct us to do so or if we are compelled by law to do so. In those cases, we will limit the disclosure to the data which are requested and strictly necessary to comply with the request. If we are compelled to disclose your data, we will notify you and provide you with a copy of the demand unless we are legally prohibited from doing so.

8. Storing, retaining & deleting your personal data

Your personal data is stored in accordance with current relevant legislation.

We need the contact information you provide to us to contact you about our products and services. You may unsubscribe from these communications at any time. For information on how to unsubscribe, as well as our privacy practices and commitment to protecting your privacy, please review our Privacy Policy.

Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose or those purposes.

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

9. Your rights

If we process your personal data, you have the certain rights flowing from the GDPR. Aside from these rights you can always withdraw your consent. If you do so, we will not process any more of your personal data from that point in time.

9.1. Right of access
You have the right to obtain confirmation as to whether or not personal data concerning you are being processed by us and if that is the case access to that information.

9.2. Right to rectification
You have the right to correct and/or complete personal data concerning yourself if those data are incorrect and/or incomplete. We will correct this without undue delay.

9.3. Right to erasure
You may require us to have your personal information deleted and we shall be obliged to erase that information immediately if one of the following situations applies:

  • your personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • You revoke your consent and there is no other legal basis for processing;
  • You object to the processing and there are no other legitimate grounds for processing ;
  • Your personal data have been processed unlawfully;
  • Your personal data have to be erased for compliance with a legal obligation.

9.4. Right to restriction of processing
You may at any time request us to restrict processing of your personal data if one of the following situations applies:

  • If you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
  • If the processing is unlawful and you would rather restrict the use of your personal data as opposed to the erasure;
  • If we no longer need the personal data for the purposes of the processing, but we are required by you for the establishment, exercise or defence of legal claims;
  • If you have objected to the processing pending the verification whether our legitimate grounds override yours.

9.5. Notification obligation
If you invoke your right to rectification, erasure or restriction of processing we shall communicate this to all recipients to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. Upon your request we will inform you about those recipients.

9.6. Right to data portability
You have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and transmit those data to another party without hindrance from us. If you wish, the personal data can also be transferred directly to a third party of your choice, where technically feasible.

9.7. Right not to be subjected to automated individual decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

This does not apply if:

  • It is necessary for entering into, or performance of, a contract;
  • It is authorised by EU or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests;
  • It is based on your explicit consent.

9.8. Right to complain with a competent supervisory authority
You have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against GDPR. Names and contact information of the competent supervisory authorities in the European Union can be found at Overview EU DPAs.

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.

10. Acting as a data processor

Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

11. Sub processors

The Processor, Pasabi, T/As Cunning Blade Ltd, has sub-contracted (part of) the processing of the Personal Data to the following Sub-Processor:

Hubspot - MA, USA

12. General terms & conditions

Please see our General Terms and Conditions for further information about the use, availability and maintenance of our services and products, the prices, liability, non-disclosure, and other general terms.

13. Changes to this privacy policy

We reserve the right to update this privacy policy from time to time. We will publish a clear notice at the top of this Privacy Policy that informs users when they were last updated.