Privacy Policy

1. Who We Are

This Privacy Policy explains how Scalability Gurus LLC, a limited liability company formed in Delaware, United States, operating under the brand name PeppitLabs (“PeppitLabs,” “we,” “us,” or “our”), collects, uses, stores, and discloses personal information.

Business address: 2604 Whittier Pl, Wilmington, DE 19808, United States
Privacy and legal contact: teampeppitlabs@yahoo.com

This Policy applies to visitors of our website, people who contact us, prospective and existing clients, people who book meetings with us, and individuals whose information we process in connection with our services.

Where we process personal data on behalf of a client, the client may be the data controller or equivalent decision-making party, and we may act as a service provider or processor. The parties’ actual roles depend on the processing activity and applicable law.

2. Personal Information We Collect

The information we collect depends on how you interact with PeppitLabs.

A. Information you provide directly

When you contact us, submit an enquiry, book a meeting, or engage our services, we may collect:

• Name, business email address, telephone number, company name, job title, and other contact details.
• Information included in enquiry forms, messages, meeting requests, and communications.
• Business requirements, project specifications, workflow information, and service preferences.
• Information reasonably necessary to prepare proposals, manage projects, communicate with clients, and provide support.
• Billing, invoicing, and transaction information necessary to administer client relationships.

Please do not submit passwords, API keys, payment-card details, or other highly sensitive information through general enquiry forms or ordinary email unless an appropriate secure process has been agreed.

B. Booking information

We use TidyCal for scheduling meetings. When you book an appointment, TidyCal may process information such as your name, contact details, selected appointment time, and any information you provide in the booking form.

TidyCal's processing of your information is also subject to its own privacy documentation and applicable terms.

C. Website and device information

Depending on the website configuration, we or our service providers may collect technical information such as:

• IP address and approximate location derived from it.
• Browser type, device type, operating system, and language.
• Pages visited, referring pages, session information, and interactions with the website.
• Cookie identifiers, advertising identifiers, and website performance information.
• Information generated through analytics, advertising measurement, heatmaps, or session-recording technologies.

The precise categories collected depend on which technologies are installed and enabled.

D. Information processed during client projects

Our AI automation, integration, and workflow services may involve processing information supplied by clients or accessed through systems they authorize us to use.

Depending on the project, this may include business contact records, customer information, workflow data, system logs, configuration information, and other data required to deliver the agreed services.

We process such information for the contracted purpose and in accordance with applicable instructions and agreements. Client project data will not be used for unrelated purposes or general internal AI training.

Clients are responsible for ensuring that they have the necessary rights and permissions to provide personal data to us and to authorize the processing required for their projects.

3. How We Use Personal Information

We may use personal information to:

• Respond to enquiries and requests.
• Schedule and manage meetings.
• Prepare proposals, deliver services, and administer client projects.
• Communicate about deliverables, invoices, support, maintenance, and contractual matters.
• Process payments and maintain business, accounting, and tax records.
• Operate, secure, maintain, and improve our website and services.
• Measure website performance and advertising effectiveness, where permitted.
• Send occasional enquiry follow-ups and relevant promotional offers, subject to applicable marketing laws and your preferences.
• Detect fraud, misuse, security incidents, and unlawful activity.
• Comply with legal obligations and establish, exercise, or defend legal claims.

We do not claim a general right to reuse client project data for unrelated purposes.

4. Legal Bases for Processing

Where required by applicable law, we process personal information on an appropriate legal basis. Depending on the circumstances, this may include:

• Contract: To take steps requested before entering into a contract or to perform a contract with you.
• Consent: Where you have given valid consent, including for tracking technologies or marketing where consent is required.
• Legal obligation: To meet applicable legal, accounting, tax, or regulatory requirements.
• Legitimate interests or equivalent lawful grounds: For appropriate business administration, security, fraud prevention, and service improvement, where permitted and where individual rights do not override those interests.
• Other lawful grounds: Where permitted under the law applicable to the particular processing activity.

If processing relies on consent, you may withdraw that consent where applicable. Withdrawal does not invalidate processing that was lawful before withdrawal.

5. Cookies, Analytics, and Advertising Technologies

Our website uses the following technologies, only after you consent:

• Google Analytics, for website analytics.
• Meta Pixel, for Facebook and Instagram measurement and advertising.

We may also use the following in future, and will update this Policy and our cookie settings before we do:

• Google Ads conversion tracking.
• Hotjar or Microsoft Clarity for website interaction analysis, heatmaps, or session recordings.
• Other technologies disclosed through our cookie settings or an updated Privacy Policy.

These technologies may collect information about website visits, interactions, device characteristics, and advertising performance.

Cookie consent

Where required by applicable law, non-essential cookies, pixels, tags, and similar tracking technologies will remain disabled until you provide the required consent.

Our consent banner allows visitors to:

• Accept non-essential tracking.
• Reject non-essential tracking.
• Manage cookie preferences by category.

You can change your preferences at any time using the Cookie settings link in the website footer.

Essential technologies necessary to provide a service you request or to maintain website security may operate without consent where the applicable legal exception permits this.

Rejecting optional tracking should not prevent access to ordinary website content unless a specific feature genuinely depends on the relevant technology.

6. How We Share Personal Information

We may disclose information to the following categories of recipients when reasonably necessary and legally permitted.

A. Service providers

Depending on the service used, recipients may include:

• Google Sheets and related Google services, for enquiry information and business administration.
• TidyCal, for appointment scheduling.
• Google Analytics, Meta, Google Ads, Hotjar, Microsoft Clarity, or other configured analytics and advertising providers.
• Stripe, Wise, and banks or payment institutions involved in processing client payments.
• Hostinger, for website hosting, and other infrastructure, security, communications, and technical support providers.
• External AI platforms and APIs selected for a particular client project.
• Contractors and specialist subcontractors engaged for a project, where applicable.

The precise providers receiving information depend on the actual configuration and project requirements.

B. Professional advisers and authorities

We may disclose information to legal advisers, accountants, auditors, regulators, law enforcement, courts, or other authorities when reasonably necessary to comply with law, protect rights, or handle legal claims.

C. Business transfers

Information may be disclosed as part of a proposed or completed merger, restructuring, financing, sale, or transfer of relevant business assets, subject to applicable legal requirements and appropriate safeguards.

D. No sale of personal information as a business model

We do not sell personal information for money as a business model. Some advertising or analytics disclosures may nevertheless be treated as “sharing,” targeted advertising, or similar regulated activities under certain privacy laws. Where applicable, we will provide the required disclosures and choices.

7. Payments

We accept or intend to accept payments through Stripe, bank transfer, and Wise.

Payment providers and financial institutions may process information such as payer identity, transaction references, payment amounts, billing details, and fraud-prevention information.

Payments are subject to the applicable provider's terms and privacy practices. We do not claim to store full payment-card numbers or security codes unless our actual payment configuration supports and requires such processing.

Clients are responsible for third-party subscriptions and usage charges for software and platforms used in their projects, unless a different arrangement is expressly agreed in writing.

8. International Data Transfers

PeppitLabs serves clients in the United States, Canada, the United Kingdom, Australia, Germany, the Netherlands, and other locations as applicable.

Because our business and service providers may operate in different countries, personal information may be processed or stored outside the country where it was collected.

Where required, we will rely on an appropriate legal basis for the transfer and implement applicable safeguards, such as contractual protections, approved transfer mechanisms, or other legally recognized arrangements.

The availability of a service provider does not, by itself, establish that every international transfer is lawful.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal obligations, dispute resolution, security needs, and legitimate recordkeeping requirements.

In particular:

• Non-client enquiries: Retained only as long as necessary for the stated purpose and applicable legal requirements.
• Client, invoicing, accounting, and tax records: May be retained for the periods required by applicable law or reasonably necessary to administer and document the business relationship.
• Project data: Retention and deletion arrangements vary by project and system. We will follow applicable project instructions and agreements, subject to legal retention requirements and technical limitations.
• Backups and security logs: May persist for a limited period under ordinary backup, recovery, and security procedures.

When information is no longer required, we will take reasonable steps to delete it, anonymize it, or otherwise dispose of it securely, where appropriate.

10. Data Security

We use reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

Depending on the systems and project, these measures may include access controls, limited permissions, secure credential handling, and appropriate service-provider safeguards.

No online system, transmission method, or storage environment can be guaranteed to be completely secure.

If a personal data incident occurs, we will assess and respond to it and notify affected individuals and relevant authorities where required by applicable law.

11. Your Privacy Rights

Depending on your location and the law that applies, you may have rights to:

• Request access to personal information we hold about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal information.
• Request restriction of certain processing.
• Object to certain processing, including direct marketing.
• Withdraw consent where processing is based on consent.
• Request a portable copy of certain information.
• Opt out of certain targeted advertising, sale, or sharing of personal information where those rights apply.
• Lodge a complaint with the relevant privacy regulator.

These rights are subject to applicable legal conditions, exceptions, and verification requirements. Not every right applies in every jurisdiction or to every category of information.

How to submit a request

Email teampeppitlabs@yahoo.com with the subject line “Privacy Request.”

Please explain your request and provide enough information for us to identify the relevant records. We may request reasonable verification to protect information from unauthorized disclosure.

We will respond within the time period required by applicable law. If a request cannot be fulfilled, we will explain the reason where legally required.

You may also contact the relevant data protection authority or regulator where applicable.

12. Marketing Communications

We may send occasional enquiry follow-ups and relevant promotional offers.

Where required, we will obtain the necessary consent before sending promotional communications. You can opt out using an unsubscribe mechanism where provided or by emailing teampeppitlabs@yahoo.com.

Opting out of marketing will not prevent us from sending essential service messages, invoices, security notices, or other communications that are not promotional and that we are permitted to send.

We will respect applicable direct-marketing laws and your preferences.

13. Third-Party Websites and Services

Our website or services may link to, embed, or integrate third-party platforms.

Those providers may collect information directly from you or through the relevant integration under their own privacy policies and terms.

We do not control every aspect of third-party privacy practices. You should review the relevant provider's documentation before using its services.

14. Children's Privacy

Our website is primarily intended for business users and individuals who can lawfully enter into the relevant arrangements. We do not impose a blanket minimum age solely for browsing public website content.

Clients commissioning services must have the legal capacity and authority required to enter into the relevant contract.

We do not knowingly seek to collect children's personal information for purposes that are prohibited by applicable law. If you believe a child has provided personal information in circumstances where collection was not appropriate, contact teampeppitlabs@yahoo.com so we can assess the request and take appropriate action.

Where a law requires parental consent, additional safeguards, or specific handling of children's data, we will comply with the requirements applicable to the relevant processing.

15. Client Data and Our Role as a Service Provider

When a client asks us to build or operate an automation, integration, or workflow, the client may determine the purposes and means of processing the information used in that project.

In those circumstances, we generally process the relevant project data only to provide the contracted services and according to the applicable instructions and arrangements.

We do not use client project data for unrelated internal purposes or general AI training.

Project-specific arrangements may address access permissions, subprocessors, data retention, deletion, security, incident handling, and handover obligations.

If you are an individual whose data is held by one of our business clients, you may need to contact that client directly to exercise certain rights. Where we receive a valid request that concerns data we process for a client, we will handle it in accordance with applicable law and our obligations to that client.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

We will publish the revised version on our website and update the effective date. We will provide additional notice or obtain consent where required by applicable law.

Material changes will not automatically override contractual or statutory rights that require separate notice or agreement.

17. Contact and Grievance Requests

For privacy questions, complaints, or requests concerning personal information, contact:

PeppitLabs Privacy & Grievance Team
Scalability Gurus LLC
2604 Whittier Pl
Wilmington, DE 19808
United States

Email: teampeppitlabs@yahoo.com

Please use the email address above for privacy and grievance matters. We will review and respond to complaints in accordance with applicable legal requirements.

Where a jurisdiction requires a formally designated grievance officer, data protection representative, or additional contact information, the relevant details will be provided as required by law.

18. Jurisdiction-Specific Rights

This Policy is intended to describe our general privacy practices. Additional rights, notices, or disclosures may apply depending on your location, the type of data involved, and the nature of our relationship with you.

Where applicable, we will comply with relevant data protection and privacy laws, including the GDPR and UK GDPR, applicable US state privacy laws, and Indian data protection law to the extent each applies to the processing in question.

Nothing in this Policy is intended to remove rights that cannot lawfully be excluded.