Privacy Policy

1. Controller and Contact Details

The data controller responsible for processing personal data under this Privacy Policy is The Scalers Limited, a company registered in Ireland (Company Number: IE3404960NH Registered Office: 13 Adelaide Road, Dublin 2, D02 P950 Ireland).

2. Introduction and Scope

This Privacy Policy explains how The Scalers Limited collects, uses, discloses, retains, and protects your personal data when you:

• visit or interact with our websites, applications, and online services (collectively, “Services”);
• use our marketing, sales, or support channels;
• register for events, newsletters, or ebooks.

This policy applies to individuals located in the European Economic Area (EEA) and, where applicable, the UK.

3. Legal Bases for Processing

We process your personal data under the following legal bases as defined in the GDPR:

• Consent (Article 6(1)(a)): where you have given consent for specific processing (e.g., marketing communications, cookies).
• Contract performance (Article 6(1)(b)): to fulfil contractual obligations when you engage with our services.
• Legitimate interests (Article 6(1)(f)): for our business operations, analytics, fraud prevention, security, and service improvements, provided your rights do not override those interests.

Where we process any special categories of data, we will identify the specific legal basis for that processing.

4. Personal Data We Collect

We collect and process the following categories of personal data:

• Identity and contact details: name, email address, phone number, job title, company name – typically provided when you contact us, register for content, or request services.
• Technical and usage data: IP address, browser type/version, device identifiers, visited pages, timestamps, and click patterns collected through cookies and similar technologies.
• Communications data: content and metadata of messages, calls, chat transcripts, meeting recordings, and AI-generated analyses where applicable.
• Cookies and tracking technologies: as further detailed in our Cookie Policy.

5. How We Use Your Personal Data

We use personal data for the following purposes, with corresponding legal bases:

• To provide, operate, and improve our Services (contract or legitimate interests).
• To communicate with you, respond to inquiries, and provide customer support (contract or legitimate interests).
• To send newsletters, marketing, and promotional communications (consent where required).
• To personalise user experience, measure engagement, and perform analytics (consent or legitimate interests).

We collaborate with the following trusted third-party service providers (subprocessors) for the purpose of communication recording, transcription, and AI-powered analysis:

• Aircall – Provides cloud-based telephony services for recording and analysing audio calls.
  
  Aircall Privacy Policy
  Aircall Subprocessors
• Apollo – Sales engagement platform with conversation intelligence features, enabling the recording and AI analysis of both audio and video communications.
  
  Apollo Privacy Policy
  Apollo AI Policy
• Google Meet (Workspace) – Used for audio and video conferencing; offers transcription and smart note-taking features powered by Duet AI / Gemini.
  
  Google Workspace Privacy Notice
  Google Meet Help Center – Recording
  Google AI Commitments
• Supernormal – AI-powered meeting assistant that joins meetings, records both audio and video, and generates transcriptions and summaries using OpenAI models.
  
  Supernormal Privacy Policy
  Supernormal Security Overview

6. Recipients and Third-Party Processors

We may share personal data with:

• Service providers and subprocessors who perform services on our behalf (hosting, analytics, CRM, marketing automation, communication tools).
• Legal authorities or regulators if required by law.

All subprocessors are contractually required to implement appropriate technical and organisational measures to protect your data.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the EEA, including the United States. When doing so, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses adopted by the European Commission or other acceptable transfer mechanisms under the GDPR.

If you want a copy of these safeguards, contact us at the email above.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or to comply with legal obligations. The retention period is determined based on the type of data and the purpose for which it was collected.

9. Your Rights

Under the GDPR, you have the following rights in relation to your personal data:

• Right of access – request copies of your personal data.
• Right to rectification – ask for incorrect or incomplete data to be corrected.
• Right to erasure (“right to be forgotten”) where processing is no longer necessary.
• Right to restriction of processing under certain conditions.
• Right to data portability – receive your data in a structured format.
• Right to object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent at any time where processing is based on consent.
• Right to lodge a complaint with a supervisory authority in your EU Member State.

To exercise these rights, contact us at the details above.

10. Cookies and Tracking

We use cookies and similar technologies to provide site functionality, context-aware content, analytics, advertising personalisation, and performance measurement. You control your cookie preferences via our Cookie Policy and consent banner.

11. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, and destruction, in accordance with applicable legislation.

12. Links to Other Sites

Our Services may contain links to third-party sites. This policy does not cover the privacy practices of those sites. You should review those sites’ privacy policies before providing any personal data to them.

13. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will post the updated policy on our website with the effective date.