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Privacy Policy

Privacy Policy

Effective date: June 01, 2018

Last update: June 01, 2018

 

 

The EU General Data Protection Regulation (GDPR) effective from May, 28th, 2018 gives all EU citizens more rights and protections for their personal data, to minimise the possibility of theft and fraud.

These regulations include provisions for the following areas:

  • The right to be informed: Companies must publish a privacy notice, in addition to explaining transparently how they use these personal data.

  • The right of access: Individuals have the right to demand details of any of their data that a company may hold. This information must be provided within one month of the request at no charge to the individual.

  • The right to rectification: If a person’s data is incorrect or incomplete, he or she has the right to have it corrected. If the company that holds the information has passed any of that information to third parties, the company must inform the third party of the correction and inform the person which third parties have their personal data.

  • The right to be forgotten: A person may request the removal of his or her personal data in specific circumstances.

  • The right to restrict processing: Under certain circumstances, an individual can block the processing of his or her personal data.

  • The right to data portability: A person can access their data for their own use anywhere they prefer.

  • The right to object: A person can object to the use of their personal data for most purposes.

1. Introduction

ScaleUpCare ("us", "we", or "our") operates the https://www.scaleupcare.com (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy, unless otherwise defined in this Privacy Policy.

Our core principles regarding user privacy and data protection

  • User privacy and data protection are inviolable human rights

  • We have a duty of care to people contained within our data

  • Data are a liability: they  should only be collected and processed when absolutely necessary

  • We despise spam in all its forms

  • We will never sell, rent or otherwise distribute or make public any personal information

2. Relevant legislation

Alongside our business and internal computer systems, this ScaleUpCare website is designed to comply with the following national and international legislations with regards to data protection and user privacy:

 

 

PT Data Protection Act – Act 67/98 of 26 October

 

EU Data Protection Directive 1995 (DPD)

 

EU General Data Protection Regulation 2018 (GDPR)

 

 

This site’s compliance with the above legislation, all elements of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0 below) for clarification.

3. Definitions
3.1. Personal Data

 

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

 

3.2. Usage Data
 

‘Data subject’ is any living individual who is the subject of Personal Data;

 

3.3. Processing
 

‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or

destruction;

 

3.4. Restriction of Processing
 

‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

 

3.5. Profiling

 

‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

​
3.6. Pseudonymisation
 

‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

 
3.7. Filing System

 

‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;

 
3.8. Controller
​

‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

 
3.9. Processor
 

processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

 
3.10. Recipient
 

 ’recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

 
3.11.    Third Party


‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

 

3.12.    Consent


‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;


3.13.    Personal Data Breach


‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;


3.14.    Genetic Data


‘genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;


3.15.    Biometric Data


‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;


3.16.    Data Concerning Health


‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;


3.17.    Sensitive Personal Data


‘sensitive personal data’ are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data. Data relating to criminal offences and convictions are addressed separately (as criminal law lies outside the EU's legislative competence);


3.18.    Cross-border Processing


‘cross-border processing’ means either:

 

  • processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or

  • processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.

 

3.22.    Usage Data


‘usage data’ is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).


3.23.    Cookies


‘cookies’ are small pieces of data stored on a User’s device.


3.24.    User


The ‘user’ is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

 

 

4.    Information Collection And Use


We collect several different types of information for various purposes to provide and improve our Service to you.


 This website collects and uses personal information for the following reasons:


4.1.    Personal Data


While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

 

  • Email address

  • First name and last name

  • Phone number

  • Address, State, Province, ZIP/Postal code, City

 

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, in case you authorize us to. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.


4.1.1.    Sensitive Personal Data


ScaleUpCare has a special concern about ‘sensitive personal data’ of their clients. The access to this type of data is limited to the client and client-selected psychologist. Only under special conditions, the client may consent that its data be revealed to another person. This consent must be written.

 

4.2.    Usage Data


We may also collect information about how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.


4.3.    Tracking & Cookies Data


We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:

 

 

  • Session Cookies. We use Session Cookies to operate our Service.

  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies. We use Security Cookies for security purposes.


5.    Use of Data


ScaleUpCare  uses the collected data for various purposes:

 

  • To provide and maintain our Service

  • To notify you about changes to our Service

  • To allow you to participate in interactive features of our Service when you choose to do so

  • To provide customer support

  • To gather analysis or valuable information so that we can improve our Service

  • To monitor the usage of our Service

  • To detect, prevent and address technical issues

 

To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information


5.1.    Use of Sensitive Data


ScaleUpCare has special attention to all ‘sensitive data’, such as ‘data concerning health’ collected or produced in consultation with our healthcare professionals. All of this data is stored encrypted and is accessible only by the health professional who executed the consultation. The owner of this data is the ' client ' and can request the ScaleUpCare to send or access it.


 6.    Retention of Data


ScaleUpCare will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
ScaleUpCare will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

 

7.    Transfer Of Data


Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Portugal and choose to provide information to us, please note that we transfer the data, including Personal Data, to Portugal and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
ScaleUpCare will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.


8.    Disclosure Of Data

8.1.    Disclosure for Law Enforcement


Under certain circumstances, ScaleUpCare may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).


8.2.    Legal Requirements


ScaleUpCare may disclose your Personal Data in the good faith belief that such action is necessary to:

 

  • To comply with a legal obligation

  • To protect and defend the rights or property of https://www.incognito.london   

  • To prevent or investigate possible wrongdoing in connection with the Service

  • To protect the personal safety of users of the Service or the public

  • To protect against legal liability


9.    Security Of Data


The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.


10.    Your Rights


ScaleUpCare aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:

 

 

  • To access and receive a copy of the Personal Data we hold about you

  • To rectify any Personal Data held about you that is inaccurate

  • To request the deletion of Personal Data held about you

 

You have the right to data portability for the information you provide to ScaleUpCare. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.


11.    Service Providers


We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


12.    Analytics


We may use third-party Service Providers to monitor and analyze the use of our Service.


12.1.    Google Analytics/Site Visitation Tracking


Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Like most websites, this site uses Google Analytics (GA) to track user interaction.
We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to track their journey through the website.
Although GA records data such as your approximate geographical location, device, internet browser and operating system, none of this information personally identifies you to us.
GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor.
GA makes use of cookies, details of which can be found on Google’s developer guides.
For your information, our website uses the Wix implementation of GA.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on link https://tools.google.com/dlpage/gaoptout. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/


13.    Behavioral Remarketing


Our third party service providers may use remarketing services to advertise on their websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.


14.    Contact forms and email links


Should you choose to contact us using the contact form on our Contact Us Page.  Only your e-mail will be stored on this website so you can access your account. No Data provided to us using said contact form will be passed to/ processed by any of the third party data processors defined below.
Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.


15.    Email newsletter


If you choose to join our regular newsletter mailings (which is sent via email), the email address that you submit to us will be stored in our Wix website platform in the 'Shout Out' database, which we use for our email marketing. We consider Wix to be a third party data processor. The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.
Your email address will remain within the Wix 'Shout Out' database on our website for as long as we continue to use the Wix platform for email marketing or until you specifically request removal from the list.
You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal by email link to go here. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 13 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the Wix 'Shout Out' database, you will receive occasional newsletter-style emails from us.


16.    How we store your personal information


If you have acquired some health care service from this website, then, your details (not including any financial details) are stored in our Wix 'Engage' database so that we can fulfil your order(s) and also to refer back to your email and/or postal details in order that we may track any orders you have queries on. No financial information is stored or used by us as all our transactions are made within the PayPal platform which does not retain any financial information once the transaction has been processed.
These data are currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (Wix). In the near future, we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.


17.    About this website’s server


This website is hosted in data centres in the United States and Europe. From time to time, we may transfer hosting from one location to another. Notwithstanding the above, the Wix.com platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles. Wix.com guarantees that the platform will be compliant with the new regulation from May 2018.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.


18.    Twitter


Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy


19.    Facebook


Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation 


20.    Wix


What Wix do to ensure data protection to all our customers

 

  • Wix employs full-time security consultants, dedicated to the security of our customer information.  

  • Wix is Payment Card Industry Data Security Standards (PCI DSS) compliant and is accredited as a level 1 service provider and merchant. This standard helps create a secure environment by increasing cardholder data, thus reducing credit card fraud. Wix regularly perform internal security audits to maintain our ISO/PCI security certifications, as illustrated below (please click the links to see the Certificates):

 

o    ISO 27001:2013 and ISO 27018:2014 Best Practices Certificate
o    ISO 27108 Certificate
o    PCIDDS Compliance Certificate

 

  • Wix's signup and login services are completed through a secure server (HTTPS/SSL). 

  • Wix uses cryptography hash functions to protect your information. Your password is stored as a hash digest and, in the event of a security breach, your original password cannot be recovered from ours or Wix servers. 

  • Wix is certified under the EU-US Privacy Shield Framework and the Swiss-US privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, and therefore adheres to the Privacy Shield Principles.

 

Wix has been carefully chosen and all of them comply with the legislation set out in the above section 2.0.
One of the following third parties are based in the USA and one is based in the Republic of Ireland and all are EU-U.S Privacy Shield compliant. https://www.privacyshield.gov/welcome

 

 

 

21.    Links To Other Sites


Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


22.    Children's Privacy


Our Service does not address anyone under the age of 13 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


23.    Data breaches


We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.


24.    Data controller


The data controller of this website is:
Pedro Gomes (ScaleUpCare Owner) pmsilvagomes@gmail.com


25.    Changes To This Privacy Policy


We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


26.    Contact Us


If you have any questions about this Privacy Policy, please contact us:

 

 

ScaleUpCare – Pedro Gomes
R. Joaquim Francisco Seabra, 98
4470-311 Maia - Portugal

 

J une 01 2018 Privacy Policy of https://www.scaleupcare.com

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