Privacy Policy | Scal-e
Scal-e is a wholly owned trademark of Polarista Group, S.L. Scal-e is a provider of software solutions, B2B data for sales and marketing activities as well as service provider related to marketing activities performed on behalf of customers. This privacy policy describes how Scal-e handles procedures related to data and in what relation Scal-e acts as a Data Controller or Data Processor. This Privacy Policy statement is of a general character related to both data security and other data usage by Scal-e, a summary of matters related to General Data Protection Regulation may be found here. This policy shows Scal-e’s internal standards of Privacy Protection addressed both in daily activities as well as in all activities related to this webpage.
1. DEFINITIONS
“Beneficiary or Customer” means any company or person entering a contractual relation with Scal-e due to provided Service or Product.
“Marketing and Sales Activities” means all activities related to service provided by the Company especially in the field of research, preparation of databases of targeted prospects, planning commercial actions, building brand awareness, performing outreach activities.
“Service” means all activities established in the Contract, as performed in line with marketing and sales purposes for the benefit of Beneficiary.
“Data Controller” means a person who defines why and how data is being processed.
“Data Processor” means anyone who processes data on behalf of Data Controller and in accordance with Controller’s will and agreed instruction.
“Data Subject” means anyone whose data is being processed.
“Visitor” means anyone who visits this website.
2. WHO WE ARE?
Scal-e may act as either Data Controller or Data Processor in following situations.
- Scal-e acts as Data Controller in relation to data of our Customers entrusted to us for the purpose of, for example, contract establishment or addressing potential questions concerning our service. Once you contact us via our webpage contact form or email, you entrust us your data and, consequently, we act as Data Controller. Furthermore, Scal-e acts as Data Controller in relation to data collected via Cookies – more about Cookies Policy available here.
- Scal-e acts as Data Controller in relation to data processed for its own marketing and sales activities defined solely by Scal-e and only for the benefit of Scal-e.
- Scal-e acts as Data Controller in relation to data of our Employees and potential Candidates applying for open positions via our job portal and entrusting us their data.
- Scal-e acts as Data Processor once being chosen to process data on behalf of the Customer who is responsible for decision making regarding how, to what extent and when data shall be processed. Such relation is implied by the Contract signed between parties.
3. WHAT INFORMATION WE COLLECT?
During the course of Marketing and Sales Activities, acting either as Data Processor or Data Controller, Scal-e may collect following categories of data:
- Name
- Job title
- Company Details
- Email address
- Phone number
- Contextual information necessary to perform Service for the customer or necessary during the course of our own marketing or sales activities.
This list is not exclusive and serves as an indication of most often examples. Each activity performed by Scal-e may include some but not all of the information included in this example. Furthermore, it may be modified on the request of Data Controller.
What is more, Scal-e may collect:
- Information about your computer and about your visits to and use of this website, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views.
- Information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our products or services.
- Information that you provide to us for the purpose of registering with us.
- Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters.
- Any other additional information you decide to share with us.
- Information relating to your interaction with our communications, such as whether an email was opened, which links were clicked, and similar engagement metrics, where you have consented to receiving and to the measurement of such communications.
4. WHY WE NEED THOSE DATA?
Scal-e collects data in different circumstances, major scenarios are described below. Scal-e may collect data or information to:
- Answer your question concerning our Product or Service, prepare pricing or detailed offer.
- Administer this webpage, help you in case of any quests and improve your browsing experience by personalizing the website.
- Send statements and invoices to you and collect payments from you.
- Send you general (non-marketing) commercial communications.
- Send you email notifications which you have specifically requested or update you when such action is necessary.
- Ask clarification questions regarding data processing performed on behalf of Data Controller.
- Send you our newsletter and other marketing communications relating to our business, and measure how you interact with them (such as opening rates and clicks) in order to improve their relevance, where you have given your consent to both receiving and having such communications measured. This single consent covers both the sending and the measurement of these communications, which serve the same purpose. You can withdraw your consent at any time — as easily as it was given — by using the unsubscribe option included in every marketing communication we send you or by contacting us at gdpr@scal-e.com. Withdrawal stops both the sending and the associated measurement.
- Statistic and research purposes presented in a form not containing personal data.
- Deal with enquiries and complaints made by or about you relating to the website.
- Contact individuals during the course of Marketing or Sales activities performed on behalf of Data Controller.
5. CUSTOMER’S DATA DISCLOUSURE
In addition to the disclosures reasonably necessary for the purposes identified elsewhere in this privacy policy, we may disclose information about you:
- To the extent that we are required to do so by law.
- In connection with any legal proceedings or prospective legal proceedings.
- In order to establish, exercise or defend our legal rights in case of any legal or administrative proceeding.
- To the purchaser [or prospective purchaser] of any business or asset which we are [or are contemplating] selling.
In addition to Scal-e, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the service provided (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, etc.) appointed, if necessary, as Data Processors by Scal-e.
Except as provided in this Privacy Policy, we will not provide your information to third parties.
6. RIGHTS AND HOW TO EXECUTE THEM?
Once acting as Data Controller, Scal-e is obliged to grant possibility to delete, correct or return data. Where your information is processed by Scal-e or if you are from the European Union or European Economic Area you have certain rights concerning processing standards guaranteed by General Data Protection Regulation. You can find more about your data protection rights in our GDPR compliance statement available here.
Once acting as Data Processor, Scal-e shall obey notification duty towards Data Controller and notify about any direct request to delete, correct or return data. Furthermore, Scal-e is obliged not to perform any action without a written request from Data Controller. Such request may be delivered via email to gdpr@scal-e.com.
7. ASSISTANCE IN CASE OF RISK ASSESSMENT
Scal-e is dedicated to ensuring an adequate level of protection internally as well as to assist Data Controllers in their duties. That is why, as Data Processor, we are willing to assist in case of Risk Assessment preparations by providing necessary information to assess the risk arising out of choosing us as Data Processor. Such help needs to be reasonably bounded by what is possible from business and technical perspective and should not raise any costs to Scal-e.
8. LEGAL BASIS FOR DATA PROCESSING
If you decide to contact Scal-e via our webpage contact form (including job applications) or directly via email, we process your data on the basis of our legitimate interest in responding to your request or handling your claim, and, where applicable, in order to take steps at your request prior to entering into a contract. Contacting us does not by itself constitute consent to receive marketing communications.
If we collect your data as Data Processor on behalf of Data Controller we either rely on consent collected by Data Controller or on their Legitimate Interest. Scal-e shall not be responsible for the quality of consent forms on the opt-in procedure performed by the Controller.
Where we send you marketing communications and measure your interaction with them, we rely on your consent, given through a clear affirmative action (an unticked, freely selected opt-in box), in accordance with Articles 4(11) and 7 of the General Data Protection Regulation and Article 82 of the French Data Protection Act (Loi Informatique et Libertés) transposing the ePrivacy Directive. This consent covers both the receipt and the measurement of these communications. It is free, specific, informed and unambiguous, and may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
9. POLICY AMENDMENTS
Scal-e reserves its right to update or amend this Privacy Policy. At the same time, by current Privacy Policy, we understand the one present at this webpage.
10. CONTACT
If you have any concerns regarding data safety, how we keep data or what measures we provide you can always contact us via gdpr@scal-e.com.