Privacy Notice

Privacy notice

1. About this notice

Scalably Inc. (“we”, “us”, and “our”) will process your personal data in compliance with all applicable laws and any laws that replace them in the future. In this notice, we have provided information based on such laws related to the processing of your personal data. This notice sets out the basis on which any personal data that you provide to us, or that we obtain about you from other sources, will be processed by us. Please ensure that you read and understand this notice.

Some personal data may be subject to other privacy policies issued by us. In such cases, this notice will supersede such other privacy policies in the case where the clauses set forth in such privacy policies contradict the clauses set forth in this notice

2. Definitions

In this notice:

a. your “personal data” means any information relating to an identified or identifiable natural person (“data subject”);

b. “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, regardless of whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction; and

c. “controller” means a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing of personal data.

3. How we collect your personal data and what personal data we collect

When you visit our website or use our service, we may automatically collect, store, and/or use technical information about the device you use to access our website and your interactions with our website or service. This information will be sent from your device to us through cookies. Please see our cookie policy for more information about our use of cookies and how to disable them.

We may receive personal data about you when you contact us on our website, via email, or by phone, and such personal data may include your name, address, e-mail address, phone number, and the details of your communications, inquiries, and responses.

We will collect your e-mail address when you register your information on our website or use our service. We may also obtain personal data about you if you post such personal data on our website or provide it in the course of using our service.

4. Legal bases and purpose of processing personal data

We will process your personal data on the following legal bases:

a. Legal Obligation. This refers to cases where we are required to comply with a legal obligation.

b. Performance of Contract. This refers to cases where the processing of your personal data is necessary for the performance of a contract to which you are party or in order to take certain steps at your request prior to entering into the contract.

c. Legitimate Interests. This refers to cases where the processing of your personal data is necessary for legitimate interests pursued by us or a third party, such as promoting our business, and where your interests and fundamental rights do not override those interests.

d. Consent. This refers to cases where you have provided your consent to our processing of your personal data. However, even if we obtain such consent from you, we may process your personal data based on other legal grounds. The withdrawal of your consent (please see Section 9(g) of this notice below) will not affect the lawfulness of our processing of your personal data based on the consent provided before the withdrawal thereof.

We will use the personal data that we hold about you only to the extent of fulfilling the purposes listed below.

a. Identifying you as a service user when you use our service (based on performance of contract or legitimate interest);

b. Communicating with you, including responding to your questions, inquiries, or messages (based on your consent or legitimate interests);

c. Analyzing data obtained through our website and service and improving our website and service (based on your consent or legitimate interests);

d. Sales activities, including sending you direct mail regarding our service (based on your consent or legitimate interests);

e. Complying with any laws or regulations applicable to us (based on a legal obligation); and

f. Cooperating with relevant governmental authorities and agencies, including competent data protection authorities and those that are engaged in administrative or criminal investigations (based on a legal obligation or legitimate interests).

We will not process your “sensitive data” (i.e., information about your race, ethnic origin, religion, physical or mental health, political opinions, sexual orientation, any actual or alleged criminal offences, or genetic and biometric data).

5. Disclosure of personal data to recipients

We may share your personal data with others in the cases described below:

a. Internal Use by Us: We may share your personal data with our employees who are authorized and need to access such data.

b. Affiliates: We may share your personal data with our affiliates for internal administrative purposes and uses that are consistent with this notice.

c. Service Providers: We may share your personal data with third-party service providers who perform services (such as providing data servers).

d. Legal Process and Safety: We may disclose your personal data to legal or government regulatory authorities as required by any applicable laws. We may also disclose your personal data to third parties as required by any applicable laws in connection with claims, disputes, or litigation, when otherwise required by any applicable laws, if we determine that such disclosure is necessary to protect the health and safety of you or others, or to enforce our legal rights or contractual commitments that you have entered into.

e. Business Transfers: Your personal data may be disclosed as part of a corporate business transaction, such as a merger, acquisition, company split, business transfer, joint venture, or the financing or sale of company assets, and may be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership.

6. Transfer of personal data outside the European Economic Area and the United Kingdom

The personal data that we hold about data subjects in the EEA and/or UK may be transferred to, and stored by, a third party outside the EEA and/or the UK. In the cases where we transfer such personal data outside the EEA and/or the UK, we will ensure that:

a. the recipient destination has been found by the European Commission to ensure an adequate level of protection of the rights and freedoms possessed by data subjects in regard to their personal data, and/or the Government of the UK has specified the recipient destination as a country that ensures an adequate level of protection as provided under the Data Protection Act 2018; or

b. the recipient has entered into standard data protection clauses with us that have been approved by the European Commission and/or the Government of the UK.

You can obtain more details of the protections given to personal data when it is transferred outside the EEA and/or the UK by contacting us using the information about us indicated in Section 12.

7. Storage limitations of personal data

We will retain your personal data for the period necessary to process it, unless we are required by any applicable laws to retain it for a longer period of time, in which case we will retain it for the period required by such applicable laws. In regard to the storage period for cookies, please see our cookie policy.

8. How we protect your personal data

We are committed to safeguarding and protecting your personal data and will implement and maintain sufficient technical and organizational measures to ensure an appropriate level of security to protect your personal data from accidental or unauthorized destruction, loss, alteration, disclosure, or access. You can obtain more details about our technical and organization measures by contacting us using the information about us indicated in Section 12

9. Your rights

You have a variety of legal rights in relation to the personal data that we hold about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and us, but typically will include:

a. the right to obtain information regarding the processing of your personal data and to access the personal data that we hold about you;

b. the right to request rectification of your personal data if it is inaccurate or incomplete;

c. the right to request erasure of your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:

i. it is no longer necessary for us to retain your personal data for the purposes for which we collected it;

ii. we are only entitled to process your personal data with your consent, and you withdraw such consent; or

iii. you object to our processing of your personal data for legitimate interests, and such legitimate interests do not override your own interests, rights, or freedoms;

d. the right to request that we restrict our processing of your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:

i. you dispute the accuracy of your personal data (but only for the period of time necessary for us to verify its accuracy);

ii. we no longer need to use your personal data except for the establishment, exercise, or defence of legal claims; or

iii. you object to our processing of your personal data for legitimate interests (but only for the period of time necessary for us to assess whether such legitimate interests override your own interests, rights, or freedoms);

e. the right to object to our processing of your personal data;

f. the right to receive any personal data which we process about you on the basis of your consent (as opposed to any other legal grounds) and where such processing is carried out by automated means in a structured, commonly used, and machine-readable format and/or to request that we transmit that data to a recipient where doing so is technically feasible. Please note that this right only applies to personal data which you have provided to us; and

g. the right to withdraw your consent to our processing of your personal data at any time. However, please note that we may still be entitled to process your personal data if we can rely on other legal grounds for doing so.

You can exercise your rights by contacting us using the information about us indicated below in Section 12. You can also file a complaint with the competent data protection authority if you believe that any of your rights have been infringed by us.

10. Changes to this privacy notice

We may modify this notice from time to time and will post an updated notice as necessary. We recommend that you review this notice periodically. If we make any material changes to this notice, you will be provided with appropriate notice, such as notice of such change being posted on our website.

11. Links to Third-Party Websites

Our website may contain links to and from third-party websites. These websites and any services that may be accessible through them have their own privacy policies. We are not responsible for other websites’ privacy practices. Please note when you leave our website and ensure that you read the privacy policies applicable to third-party websites.

12. Contacts

Any questions, comments, or requests regarding this notice are welcome. Please contact us using the information below.

Controller (us):

Name: Scalably Inc.

Representative Director: Junya Yamamoto

Main Office Address: 5F Daini Oishi Building, 4-1-6 Toranomon, Minato-ku, Tokyo, Japan

Address: info@scalably.com

Privacy notice

Scalably uses the cookies indicated below for the purposes set forth in this Cookie Policy. Cookies are small files which are stored on your devices.

Essential Cookies

These types of cookies are necessary for our website to function properly, and cannot be disabled in our system. Normally, these types of cookies are provided only in response to your request for services, including privacy settings, login or form input, etc. You may set your browser to block these cookies or issue warnings related to these cookies, but in that case, it is possible that parts of our website will not function properly.

If you are located in the EEA or UK, and your information processed in relation to the essential cookies constitutes personal data, then the legal bases for such processing are the legitimate interests for us to operate our website.

Our website uses the following essential cookies.

Cookie Name	Source	Purpose of Use and Explanation	Expiration Date
wp-wpml_current_language	scalably.com	It stores the languages which are currently displayed.	No Expiration
wp-activate	scalaby.com	It is set when a user clicks on the activation link in the email. It helps the site recognize and associate the user’s browser session.	browser session
scalaby.com	scalaby.com	It is set to check whether the cookie is enabled on the client side.	browser session
comment_cookie_lifetime	scalably.com	Store an unauthenticated commentator's identity	365 days
wp-postpass	scalably.com	allow access to password-protected content for a specific post	10 days
wp-resetpass	scalably.com	It is stored to check whether users intent to reset password	browser session
wp-settings	scalably.com	Store settings of users	365 days
wp-saving-post	scalably.com	Cookie flag to mark post was saved	24 hours
pll_language	scalable.com	store user preferred language	365 days
wordpress_logged_in	scalably.com	It is used to confirm whether the current visitors are logged-in users.	14 days