Privacy Policy

Prolarys CommV, trading as ScaleUP Security

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Prolarys CommV, trading as ScaleUP Security ("ScaleUP Security", "we", "us" or "our") is a cybersecurity and compliance consulting company. We help startups and growing SaaS businesses achieve, maintain and grow security certifications and compliance programs such as SOC 2, ISO 27001, PCI DSS, GDPR and similar frameworks. We have prepared this Privacy Policy ("Policy") to summarize our online data protection practices. This Policy explains why we gather information, what types of information we collect, and how we use it.

We collect personal information when:

This Policy explains how the information you provide through our website is used, how you, as a data subject, can control the use of your personal data, and how to communicate with us on this subject if needed. It also explains why our website does not use cookies.

WHO WE ARE AND WHO IS RESPONSIBLE FOR YOUR DATA

ScaleUP Security operates through two legal entities:

Prolarys CommV is the controller of the personal data processed through this website and of your communications with us — that is, the entity that determines the purposes and means of the processing. Where we pass your inquiry to ScaleUP Security Inc. so that it can serve you, ScaleUP Security Inc. becomes the controller of the data it receives and handles it in accordance with PIPEDA.

You may contact either entity on any privacy-related matter at hello@scaleupsec.com.

WHAT TYPES OF DATA ABOUT YOU DO WE COLLECT?

Data minimization. As a cybersecurity and compliance company, we apply the principle of data minimization to our own website. We collect only the limited personal data that is genuinely necessary to operate the website, respond to your inquiries and meet our legal obligations — and nothing more. We do not sell your personal data, and we do not use it for purposes that are incompatible with those described in this Policy. Please note that, under the GDPR, "personal data" is broad and includes online identifiers such as IP addresses and device identifiers; where we collect such data, we treat it as personal data and handle it in accordance with this Policy.

Subject to the above, we may collect the information described below, and we use it only to the extent set out in this Policy.

Information you provide to us

If you contact us by email, you provide personal data such as your name, email address, the content of your message and any information you choose to include. If you book a call through our scheduling tool (Calendly), you provide your name, email address, the time you choose and any answers to the optional booking questions, such as your company, what prompted the call and your deadline.

Information we obtain when you use and visit our website

When you visit our website, the following limited information is processed:

WHY DO WE PROCESS YOUR PERSONAL INFORMATION?

We process your data only where we have a legal basis to do so. The legal basis depends on the reasons for which we collected your personal data and on the need to use it. Your personal data may be processed for the following purposes:

More specifically, the personal data you submit through this website, and the personal information we collect from you, will be used on the following legal grounds.

Communications — based on steps taken at your request before entering into a contract, Art. 6(1)(b) GDPR, and our legitimate interest in responding to inquiries, Art. 6(1)(f) GDPR:

If you have contacted us through our website, your data may be processed to enable us to answer your questions and to arrange a call, meeting, video conference or other communication. Please note that such communications may be recorded and stored by a ScaleUP Security representative in our corporate systems.

Website analytics — based on our legitimate interest, Art. 6(1)(f) GDPR:

We use aggregated, cookieless statistics to understand how visitors use our website and to improve its content. These statistics do not identify you, and we do not use them for advertising or profiling.

Business relations— based on ScaleUP Security's legitimate interest, Art. 6(1)(f) GDPR:

As a representative of a current or potential client, business partner or vendor, your personal data may be processed for the following purposes:

Security — based on ScaleUP Security's legitimate interest, Art. 6(1)(f) GDPR:

As a visitor to this website, your personal data may be processed to keep the website secure, prevent fraud, protect the rights and interests of ScaleUP Security and third parties, and protect intellectual property rights.

WHO RECEIVES YOUR DATA?

We share your personal data only with service providers that help us run our website and our business, and only as far as they need it:

Some of these providers process data outside the European Economic Area, for example in the United States or Canada. In such cases we rely on an adequacy decision of the European Commission (such as for Canada, or for US companies certified under the EU–US Data Privacy Framework) or on the European Commission’s Standard Contractual Clauses.

Your personal information may also be disclosed:

HOW CAN YOU CONTROL YOUR DATA?

As a data subject, you have the right to:

If you wish to discuss or exercise any of these rights, please contact us at hello@scaleupsec.com. We aim to respond to your request within one month.

We may need to request specific information from you to help us confirm your identity before granting access to your data or allowing you to exercise your other rights. This security measure ensures that your data is not disclosed to anyone who has no right to receive it.

HOW IS YOUR DATA RETAINED?

We take appropriate technical and organizational security measures to protect the personal information that we process, store or transmit. Your data is protected against accidental or unlawful destruction, access or alteration, unauthorized or unlawful disclosure, and loss. Your data is stored securely on our systems.

We will not retain your data for longer than is necessary for the purpose for which it is processed. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the purposes for which we process it and whether we can achieve those purposes by other means, and the periods for which we may need to retain the data to meet our legal obligations or to deal with complaints and queries, or to protect our legal rights in the event of a claim. When we no longer need your personal data, we will securely erase it.

As a guide: emails and booking details from prospective clients are kept for up to two years after our last contact, unless they become part of a client relationship. Website statistics are kept in aggregated form only.

Please note that the following information will be retained to the extent that we are required to do so by law, and where it is relevant to any prospective or ongoing legal proceedings:

This is done to establish, exercise or defend our legal rights, including providing information to others for the purposes of fraud prevention and credit-risk reduction.

DO WE USE COOKIES?

Cookies are small text files that websites place on your device. Our website does not use cookies: not for analytics, not for advertising and not for any other purpose. Our website statistics are collected without cookies (see above), which is why we do not show a cookie banner.

If you choose a language on our website, your browser may remember that choice locally on your device. This information is not sent to us, and you can clear it at any time in your browser settings. When you follow a link to an external service, such as Calendly or LinkedIn, that service’s own cookie and privacy policies apply.

YOUR PRIVACY RIGHTS IN CANADA (PIPEDA)

Where ScaleUP Security Inc., our Canadian company, handles your personal information, this is governed by Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and, where applicable, substantially similar provincial privacy legislation. In accordance with these laws:

To exercise these rights, or to ask a question or make a complaint about how we handle your personal information, contact us at hello@scaleupsec.com. If you are not satisfied with our response, you have the right to make a complaint to the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or to your applicable provincial privacy regulator.

DO YOU HAVE ANY QUESTIONS?

If you have any questions about this Privacy Policy, please contact us at any time at hello@scaleupsec.com.