Privacy Policy

Last updated: May 11, 2026

This Privacy Policy explains how Scouty AI collects, uses, stores, shares, and protects personal data when you visit or use:

https://www.scoutyai.com

and any related pages, forms, demos, communications, products, services, or business activities made available through the Scouty AI brand.

1. Who we are

Scouty AI is an international sourcing technology project operated through an affiliated company structure involving entities in Hong Kong and Bulgaria/EU.

For the purposes of this Privacy Policy, “Scouty AI,” “Scouty,” “we,” “us,” or “our” may refer to one or more of the following entities, depending on the relevant service, contract, customer relationship, funding programme, project activity, jurisdiction, or business context:

Hong Kong entity

Scouty Limited
Business registration number: 77271452-000-11-25-3
Registered address: Room A, 19/F Max Share Centre, 367–373 King’s Road, North Point, Hong Kong
Website: https://www.scoutyai.com
Email: support@scoutyai.com

Scouty Limited may be used for activities connected with Hong Kong, China, Asia-Pacific business development, international partnerships, technology commercialization, regional project participation, and related commercial activities.

Bulgaria / EU entity

Luciano International Inc.
Company registration number / UIC: 203417271
Registered address: Central District, Petar Parchevich Street No. 2, Floor 4, Office 403, Plovdiv 4000, Bulgaria

Luciano International Inc. may be used for activities connected with Bulgaria, the European Union, European funding programmes, research and development, commercial operations, business development, project implementation, and related European market activities.

Where required by law, contract, funding application, proposal, invoice, or project documentation, the relevant legal entity will be identified separately.

2. Relevant data controller

Depending on the context, the relevant data controller may be:

• Scouty Limited, where the interaction relates to Hong Kong, China, Asia-Pacific business activities, international partnerships, or services provided by Scouty Limited;
• Luciano International Inc., where the interaction relates to Bulgaria, the European Union, European funding programmes, EU-based commercial activities, research and development, or services provided by the Bulgarian entity;
• both entities jointly, where the entities jointly determine the purposes and means of processing personal data for shared business, product development, marketing, customer relationship, project implementation, or service delivery purposes.

If you are unsure which entity is responsible for your personal data in a specific context, you may contact us at:

support@scoutyai.com

3. Scope of this Privacy Policy

This Privacy Policy applies to personal data we collect when you:

• visit our website;
• contact us through forms, email, phone, or other communication channels;
• request a demo, quotation, consultation, pilot, or early access;
• subscribe to updates, newsletters, or marketing communications;
• communicate with us as a customer, prospect, supplier, partner, investor, contractor, or website user;
• use or test Scouty AI products, demos, prototypes, tools, or services;
• share sourcing, procurement, supplier, product, or business requirements with us;
• engage with us in connection with funding, partnership, research, development, or commercial projects.

This Privacy Policy does not apply to third-party websites, platforms, or services that may be linked from our website. Those third parties are responsible for their own privacy practices.

4. Personal data we collect

Depending on how you interact with us, we may collect the following types of personal data.

A. Information you provide directly

This may include:

• full name;
• company name;
• job title;
• business email address;
• phone number;
• country or region;
• company website;
• LinkedIn or professional profile;
• information submitted through forms, demo requests, support messages, or other communications;
• sourcing, procurement, product, supplier, quotation, logistics, or business requirements that you choose to share with us.

B. Business and service information

This may include:

• customer or lead status;
• inquiry and request history;
• onboarding information;
• project details;
• contract, billing, invoice, or transaction-related information;
• service usage records;
• communication history with our team.

C. Technical and website usage data

This may include:

• IP address;
• browser type and version;
• device type;
• operating system;
• referring URLs;
• pages viewed;
• clicks and session activity;
• approximate location derived from IP address;
• cookie, pixel, tag, or similar identifier data.

D. Marketing and communications data

This may include:

• communication preferences;
• newsletter or marketing subscription status;
• email opens, clicks, and campaign engagement data;
• responses to outreach or business development communications;
• records of conversations with us.

E. Information from third parties

We may receive personal data from:

• analytics providers;
• CRM and marketing tools;
• advertising platforms;
• social media and professional networking platforms;
• business partners, referrals, or suppliers;
• public professional sources, company websites, business directories, or publicly available databases.

We only use such information where we have an appropriate legal basis to do so.

5. How we use personal data

We may use personal data for the following purposes:

• to operate, maintain, and improve our website, products, demos, and services;
• to respond to inquiries, demo requests, support requests, and business communications;
• to provide sourcing, procurement, RFQ, supplier-related, software, or related business services;
• to understand customer needs, product requirements, sourcing requests, and project context;
• to create, manage, and follow up on sales opportunities;
• to manage customer, supplier, partner, investor, or contractor relationships;
• to prepare proposals, quotations, project documentation, contracts, or invoices;
• to support product development, testing, research, analytics, and service improvement;
• to personalize website content, product experience, and communications;
• to send business updates, marketing communications, event invitations, or relevant insights where permitted by law;
• to measure campaign effectiveness, website usage, and product interest;
• to protect the security, integrity, and reliability of our systems;
• to detect, prevent, investigate, or address fraud, abuse, unlawful activity, or security incidents;
• to comply with legal, regulatory, tax, accounting, corporate, or funding-related obligations;
• to establish, exercise, or defend legal claims.

6. Legal bases for processing

Where applicable data protection law requires a legal basis for processing, we rely on one or more of the following:

• Consent — where you have given us permission to process your data for a specific purpose, such as subscribing to communications.
• Performance of a contract — where processing is necessary to provide services, respond to requests, or take steps before entering into a contract.
• Legal obligation — where processing is necessary to comply with applicable laws, regulations, accounting, tax, corporate, or funding-related obligations.
• Legitimate interests — where processing is necessary for our legitimate business interests, including operating and improving our website, products, services, communications, customer relationships, security, and business development, provided those interests are not overridden by your rights and interests.

If we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that took place before consent was withdrawn.

7. Cookies and similar technologies

We may use cookies, pixels, tags, local storage, and similar technologies to:

• keep the website functioning properly;
• understand website traffic and usage patterns;
• remember preferences;
• improve website performance and user experience;
• measure campaign effectiveness;
• support analytics, advertising, and remarketing activities where permitted by law.

These technologies may include tools such as Google Analytics, Meta Pixel, LinkedIn Insight Tag, Google Ads tracking, or similar analytics and advertising tools, if and when they are implemented on our website.

Some cookies or similar technologies may be set by third-party providers that support analytics, marketing, security, embedded content, or website functionality.

You can control cookies through your browser settings and, where implemented, through our website cookie controls. Disabling certain cookies may affect website functionality.

8. How we share personal data

We may share personal data with:

• affiliated entities within the Scouty AI company structure;
• hosting, cloud infrastructure, and website service providers;
• CRM, email, marketing, and customer support providers;
• analytics and measurement providers;
• advertising and social media platforms;
• payment, accounting, legal, tax, and professional advisers;
• contractors, consultants, developers, and service providers who support our business;
• suppliers, sourcing partners, logistics partners, inspection partners, or project-related counterparties where necessary to provide requested services;
• funding bodies, project partners, accelerators, incubators, or programme administrators where relevant to a project, application, or reporting obligation;
• regulators, courts, law enforcement, or public authorities where required by law or necessary to protect rights, safety, security, or legal claims;
• counterparties in a corporate transaction such as a merger, acquisition, financing, restructuring, investment, transfer, or sale of assets.

We do not sell personal data in exchange for money.

9. International transfers

Because Scouty AI operates internationally and works with service providers, partners, and customers in multiple jurisdictions, personal data may be processed outside the country where you are located.

This may include processing in:

• Hong Kong;
• Bulgaria;
• the European Economic Area;
• the United Kingdom;
• the United States;
• China and other Asia-Pacific jurisdictions;
• other countries where our service providers, partners, or infrastructure providers operate.

Where required by applicable law, we take reasonable steps to ensure appropriate safeguards are in place for cross-border transfers of personal data.

10. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention periods may depend on:

• the duration of our relationship with you;
• the time needed to respond to inquiries or provide services;
• the period required for business, accounting, tax, audit, funding, or legal records;
• the time needed to resolve disputes or enforce agreements;
• applicable legal or regulatory requirements;
• the nature of the personal data and the purpose for which it was collected.

When personal data is no longer required, we will delete, anonymize, or securely retain it where permitted or required by law.

11. Data security

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

These measures may include access controls, secure systems, limited access to business data, service provider controls, and internal procedures.

However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

12. Your rights

Depending on your location and applicable law, you may have the right to:

• request access to personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• request restriction of processing;
• object to certain processing;
• request portability of personal data where applicable;
• withdraw consent where processing is based on consent;
• opt out of marketing communications;
• complain to a relevant supervisory or regulatory authority.

To exercise your rights, contact us at:

support@scoutyai.com

We may need to verify your identity before responding to certain requests.

13. Additional notice for Hong Kong data subjects

If the Personal Data (Privacy) Ordinance (Cap. 486) applies, you may request access to and correction of your personal data held by us.

We will handle such requests in accordance with applicable Hong Kong legal requirements.

14. Additional notice for EEA, UK, and EU users

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction where GDPR or similar data protection laws apply, you may have additional rights under applicable data protection law.

These may include rights relating to access, rectification, erasure, restriction, objection, portability, withdrawal of consent, and the right to lodge a complaint with a supervisory authority.

Where we rely on legitimate interests, you may contact us for more information about the relevant balancing assessment.

15. Marketing communications

Where permitted by law, we may send you marketing or business development communications about our products, services, updates, events, partnerships, funding activities, and insights.

You can opt out at any time by:

• using the unsubscribe link in the communication, where available;
• emailing us at support@scoutyai.com.

Even if you opt out of marketing communications, we may still send you non-marketing communications related to existing business dealings, service delivery, support, security, legal matters, contracts, or transactions.

16. Children’s privacy

Our website, products, and services are intended for business and professional users.

They are not directed to children, and we do not knowingly collect personal data from children.

If you believe that a child has provided us with personal data, please contact us and we will take appropriate steps.

17. AI-assisted tools and automated processing

We may use software, analytics, automation, or AI-assisted tools to support internal business processes, product functionality, lead qualification, sourcing workflows, RFQ preparation, service optimization, or customer support.

We do not intend to make solely automated decisions that produce legal or similarly significant effects on individuals unless we have a lawful basis and provide any legally required notices.

Where AI-assisted tools are used, they are intended to support business processes and human decision-making, not to replace professional judgment.

18. Business, sourcing, and supplier information

When you submit sourcing, procurement, supplier, product, quotation, logistics, or project-related information to us, we may use that information to:

• understand your request;
• prepare or improve RFQs;
• support sourcing or supplier-related workflows;
• communicate with relevant suppliers, partners, or service providers where necessary;
• provide quotations, analysis, recommendations, or project support;
• improve our products, workflows, and services.

You should not submit confidential, sensitive, or third-party information unless you are authorized to do so and the information is necessary for the requested service.

Where a separate confidentiality agreement, service agreement, or project agreement applies, that agreement may contain additional terms.

19. Third-party links and services

Our website or communications may contain links to third-party websites, platforms, tools, or services.

We are not responsible for the privacy practices, content, security, or policies of third parties. You should review their privacy policies before providing them with personal data.

20. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, services, legal obligations, technology, company structure, or data practices.

When we make changes, we will update the “Last updated” date at the top of this page.

Where required by law or where changes are material, we may provide additional notice.

21. Contact us

If you have questions about this Privacy Policy or our data practices, please contact:

Scouty AI Privacy Contact
Email: support@scoutyai.com

For Hong Kong-related matters:

Scouty Limited
Room A, 19/F Max Share Centre
367–373 King’s Road
North Point, Hong Kong

For Bulgaria / EU-related matters:

Luciano International Inc.
Central District, Petar Parchevich Street No. 2
Floor 4, Office 403
Plovdiv 4000, Bulgaria