Privacy Policy

Privacy Policy

1) Controller. Your Personal Data is processed by SCALEUP (Sp. z o. o./limited liability company based in Warsaw, 93/2 Wał Zawadowski Street, 02-296 Warsaw; registered under the KRS/National Court Register number: 147437; NIP/tax ID number: 5213230608; share capital: PLN 5,000.00; “Controller”) in compliance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”) and such other privacy and data protection laws as may be applicable. The Controller has not designated a data protection officer; you as a Data Subject may contact the Controller with regard to all issues related to processing of your Personal Data and to the exercise of your rights under the GDPR or other applicable privacy and data protection laws (collectively, “Data Privacy Laws”) at this email address: (“Point of Contact”).

(2) Processing. The processing carried out by the Controller may involve your first and last name, email address, and any other information relating to an identified or identifiable natural person (“Data Subject”, “Personal Data”, respectively) that you choose to disclose, transmit or otherwise voluntarily and in all conscience make available to the Controller. As a matter of rule, your Personal Data will be processed based on either consent, contract or legitimate interests. Where the legal ground for processing requires your consent, the Controller will ensure your agreement to the processing is freely given, specific, informed and unambiguous, and the request for consent is in an intelligible and easily accessible form, using clear and plain language. The Controller will inform you prior to giving consent, and hereby informs you, that you have the right to withdraw your consent at any time; however, the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Where the legal ground for processing is a contract, the Controller will process your Personal Data to the extent necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

(3) Legitimate interests. Unless and until your interests or fundamental rights and freedoms prevail over the legitimate interests pursued by the Controller or a third party, the Controller may process your Personal Data for the purpose of direct marketing, to prevent fraud or abuse, or to ensure network and information security.

(4) Recipients. The Controller may use third-party service providers and their respective resources to run its business which involves processing of your Personal Data. Thus, your Personal Data may be disclosed to, and by extension processed by, (persons or entities owning or operating under the following business or trade names or marks) MICROSOFT as long as it provides email hosting services; ZENBOX as long as it provides website hosting services; GOOGLE and HOTJAR as long as they provide analytic tools; GOOGLE, FACEBOOK and LINKEDIN as long as they provide remarketing services; and MICROSOFT as long as it provides its suite of applications – to the Controller. The recipients as listed above exemplify the categories of persons, authorities, agencies or bodies to which the Controller may disclose your Personal Data.

(5) Rights. Subject to restrictions or limitations provided for under Data Privacy Laws, you may request from the Controller access to and rectification, erasure, porting, restriction of processing of your Personal Data, and object to Controller’s processing, via, in particular, Point of Contact. The Controller will provide you with information on action taken on your request without undue delay and in any event within one month of receipt of the request; that period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Where you make the request by electronic form means, the information will be provided by electronic means where possible, unless otherwise requested by you. You may also lodge a complaint with a supervisory authority.

(6) Miscellaneous. The legal bases for processing and the exercise of your rights define the period for which your Personal Data will be stored. For example, the Controller will cease to process your Personal Data where you have withdrawn your consent or the contract you are party to has been fully performed. In principle, provision of Personal Data is voluntary; the Controller will not engage in the automated decision-making, including profiling, which produces legal effects concerning, or similarly significantly affects, you.

(7) Cookies. The Controller operates the SCALEUP website (; “Website”) and may use within the Website certain IT data (in particular, text files), stored in or accessed from your computer or mobile device, containing the name of the web page on which they were collected, the time of storage in the computer or mobile device and a unique number (“Cookies”). Cookies are used to tailor the content of the Website to your preferences, as well as to optimize the use of the Website and enhance the user experience. Cookies enable (i) the identification of your computer or mobile device in order to display web pages fitting your individual needs, (ii) compilation of reports that facilitate the understanding of how visitors use the Website and, as a result, help the Controller improve the Website, its structure and content, (iii) maintenance of your session (when logged in), owing to which, you don’t have to reenter your login and password on each web page. The Controller uses (i) strictly necessary/essential Cookies, which enable you to use the services offered by the Website, e.g. authorization cookies are used for functionalities that require authorization within the Website; (ii) security Cookies, e.g. used for the identification of authorization abuses within the Website; (iii) “high efficiency” Cookies, which enable the collection of information on how visitors use our Website; (iv) “functionality” Cookies, which store your settings and your interface personalization, e.g. language, region, font size, web page layout etc.; and (v) “advertising” Cookies, used to tailor the advertising to your interests. You can change your cooking settings at any time; detailed information on cookies handling can be found in the software (web browser) settings. The Controller hereby informs that any restrictions in the use of cookies might influence some of the functionalities accessible on the Website. Cookies placed on your computer or mobile device can also be used by the Controller’s advertisers and partners.