Processing of personal data

Scaleup Finance ApS (hereinafter “Scaleup Finance”), CVR-number 41920084, Nyropsgade 39, DK-1602 København, Denmark processes personal data about you as a customer when you visit our website, subscribe to our newsletter or attend our events. The conditions of our processing of your personal data and your personal rights in this connection are further described below in accordance with the rules of the General Data Protection Regulation (the ‘GDPR’).‍

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The roles of Scaleup Finance

When processing collected personal data on our website and when you subscribe to our newsletter etc., Scaleup Finance is data controller. 

If Scaleup Finance processes personal data, when administrating companies, this is usually done on behalf of the respective customer, so that Scaleup Finance regularly only acts as a data processor within the meaning of Article 28 of the GDPR, cf. section below regarding administrations of companies.

If you have any questions about Scaleup Finance’s processing of your personal data or you wish to exercise your rights, you are always welcome to contact us per email:

gdpr@scaleup.finance 

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Categories of personal data, purpose and governing law

As part of the administration of our customers, we are processing personal data about you. In all relationships with customers, we are processing information with a view to establishing a relationship with customers, management and performance of the business operations of a consulting firm. Below is specified the personal data processed in this connection.

Customer management

In order to administer, manage and cultivate the relationship with our customers, we process personal data about you as a customer or a potential customer. As part of our customer management, the following types of information are processed. The information is processed without regard to the field in which you are receiving advice from Scaleup Finance.

• Ordinary personal data. These include identification information and contact information such as names, email addresses and postal addresses about customers, owners of the customer and/or contact persons, as well as representatives of the customer. Furthermore, we process information about our relationship with the customer, including correspondence, and information about accounts receivable and outstanding amounts. In certain cases, we collect credit information about customers. 
  

• The legal basis for the processing is Article 6(1)(b) of the GDPR, according to which personal data can be processed if necessary, for the performance of a contract, in this case the task or the potential task. Furthermore, personal data can be processed if necessary for the purposes of Scaleup Finance’s legitimate interests, including the establishment and cultivation of a relationship with a customer, see Article 6(1)(f) of the GDPR; just as there might be situations where we store your personal data even if we do not enter into a consultancy agreement.
  
  

Money laundering

There is a number of requirements in the anti-money laundering legislation that Scaleup Finance must meet. In order to meet these requirements for the prevention of money laundering and financing of terrorism, we process personal data about you.

• Ordinary personal data. Including processing of information, such as name, Civil Registration No. (alternatively passport number or another national identification number).The information is compared with a reliable and independent source, e.g. the Danish central national register, digital signature or NemID, or copy of picture ID (e.g. passport, driver’s licence or the like), CVR number, owner and control structure, beneficial owners, alternatively the day-to-day management (must be authenticated by identity information). 
  

• The legal basis for the processing is Article 6(1)(c) of the GDPR, according to which personal data can be processed when necessary for compliance with a legal obligation. In exceptional cases, sensitive personal data can be processed, and such processing will be based on Article 9(2)(g) of the GDPR; just like information about criminal offences can be processed pursuant to Section 8(5) of the Danish Data Protection Act.
  
  

Marketing

Scaleup Finance processes personal data in connection with marketing activities, including provision of courses, events, etc., as well as sending out newsletters. Processing is necessary in order to provide services to interested companies.

• In this context, ordinary personal data are processed, including name, contact information and possible interests or preference for topics, as well as language. 
  

• The legal basis for processing of personal data in connection with courses, events, sending out newsletters, etc. is Scaleup Finance’s legitimate interests in marketing its business, see Article 6(1)(f) of the GDPR. 
  

• Scaleup Finance will only send newsletters or other marketing material to you if we receive a request to do so. If you exceptionally receive newsletters or other material from us, without having requested it, or if you no longer wish to receive such information, you may notify us at the contact details above. We will then stop sending you the respective material.
  
  

Business operations of a consulting firm

In connection with Scaleup Finance’s business operations as a consulting firm, we process personal data of owners or employees of our suppliers, customers and business partners.

• In this regard, ordinary personal data are processed, including name, place of work and contact information, as well as information about the relationship and correspondence.
  

• The legal basis is Article 6(1)(b) of the GDPR, according to which processing is necessary for the performance of a contract to which the data subject is a party or if necessary for the purposes of Scaleup Finance’s legitimate interests, see Article 6 (1) (f). Where processing is based on Scaleup Finance's legitimate interest, this is in communicating with suppliers and partners, which is essential to the operation of the business model.
  
  

Scaleup Finance's website

When you visit Scaleup Finance’s website and cloud-based software, we collect and process information about you in connection with our use of cookies for marketing and statistical purposes, e.g. to optimize our website and target ads.

You can find an outline of the types of cookies used by Scaleup Finance and how to delete them, etc. in Scaleup Finance’s Cookie Policy.

• Ordinary personal data are processed in the form of your IP address in connection with Scaleup Finance’s use of cookies. In addition, we process the following information about you: demography, including gender and age, interests, geography and information about your browser, device and service provider. 
  

• The legal basis is Scaleup Finance’s legitimate interests in generating statistics and, by this process, analyzing the use of our website, e.g. to optimize it, see Article 6(1)(f) of the GDPR.
  

• When you use the contact form on our website, we collect your name and email address. In addition, we collect your telephone number and the company name if you also provide us with this information. We process this data so that you can contact us and so that we can handle your request. The legal basis is usually Article 6 (1)(b) of the GDPR, which permits data processing for the performance or initiation of a contract. If your request is not aimed at concluding a contract with Scaleup Finance, the legal basis is Article 6 (1) (f) of the GDPR. In this respect, Scaleup Finance's legitimate interest follows from the need to open up a low-threshold contact option. 

Social media

Scaleup Finance is active on several social media, including LinkedIn, Facebook, and Instagram. When you interact with Scaleup Finance on these media, you are making information available to Scaleup Finance and the social media, e.g. when you respond to our postings, comment on or share them, just like we process information that you ‘like’ Scaleup Finance or follow us on the social media. In addition, ordinary information is processed about you in the form of, for example, identification information, contact information, your profile photo, etc. Furthermore, Scaleup Finance will in some cases share, for example, a piece of news in which your identification information (name) is included. The purpose of the processing is branding and marketing of Scaleup Finance.  

• The legal basis for the processing is Scaleup Finance’s legitimate interests in marketing us as a consulting firm on the social media and knowledge sharing in the form of sharing of articles, etc., see Article 6(1)(f) of the GDPR.
  

• When using Facebook, Facebook makes use of information collected from Scaleup Finance’s Facebook page, and Scaleup Finance and Facebook can be considered as being joint data controllers of the processing of data. You can read more about joint data control with Facebook here. 
  

• Information on the social media is deleted when Scaleup Finance deletes a posting or when you delete your comment, share, reaction or indication that you ‘like’ or follow Scaleup Finance.

Disclosure and transfer of personal data

Your personal data are disclosed only in connection with case management and only when Scaleup Finance is legally obliged to do so, or when you have given your consent. You can always withdraw your consent by contacting Scaleup Finance via the above contact information. Data may be disclosed to the following parties:

• Public authorities, including the Danish courts, the bailiff’s court, the probate court, the registration court, SKAT (the Danish tax authorities), the prosecuting authority, the Danish Rent Tribunal, the Danish Ministry of Justice, etc. 
  

• Insurance companies and banks
  

• The Danish State Prosecutor for Serious Economic and International Crime (SØIK)
  

In addition, Scaleup Finance discloses your personal data to data processors, who are assisting Scaleup Finance in our business operations. Data processing agreements in accordance with Article 28 (3) GDPR have been concluded with these processors to ensure the protection of your data. The data transfers to these processors shall only take place in accordance with the provisions of the agreements concluded.

In principle, Scaleup Finance does not transfer your information to countries outside the EU/EEA. However, transfer may take place if you or a party to our services is located in a so-called third country. In this case, the legal basis is Article 49(1)(c) of the GDPR, according to which a transfer is permitted if it is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person.  The transfer may also take place if you have given your consent after having been informed of the possible risks of such transfers according to Art 49 (1) (a) of the GDPR.  You can always withdraw your consent by contacting Scaleup via the above contact information.

Confidentiality

All Scaleup Finance’s employees are subject to strict confidentiality, including the processing of personal data. 

Erasure

In general, Scaleup Finance processes your information only as long as it is necessary to fulfil the purpose of the processing. In detail, the following erasure periods apply: 

Customer management and money laundering

In connection with customer management Scaleup Finance generally stores your information for five years from the end of the year in which the case was closed, unless otherwise required according to legislation or in case of original documents, such as, contracts, etc. 

Information for money laundering control purposes, etc. is stored for five years pursuant to the money laundering legislation after customer relations have ended.

Business operations of a consulting firm

Information about you as a supplier or cooperating partner is stored for up to five years after the end of the year during which the delivery took place or the cooperation was terminated.

Marketing and website

Scaleup Finance stores your information for up to two years after you have participated in an event or unsubscribed to our newsletter. 

For deletion of cookies, see Scaleup Finance ’s Cookie Policy.

Rights

As a data subject, you have certain rights according to the GDPR when your personal data are being processed. Below is a specification of your rights when Scaleup Finance processes personal data about you. If you want to exercise one or more of your rights as a data subject, you must contact Scaleup in writing via the e-mail address indicated above. Please state your full name and your e-mail address. You may be requested to provide further identification. In general, you can exercise your rights at any time. However, exercising your rights must not affect the rights and freedoms of others and in such an event, Scaleup Finance may therefore refuse to comply with your rights wholly or in part in compliance with the GDPR and other applicable legislation. 

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Right of access 

As a data subject, you have the right to obtain access to your personal data being processed by Scaleup Finance. By contacting Scaleup Finance, you can obtain information about the categories of personal data that we as data controller are processing about you, the purpose of the processing, the recipients to whom the personal data have been disclosed, etc. We will provide you with a copy of your personal data undergoing processing. If you request further copies of your personal data undergoing processing, Scaleup Finance may charge a reasonable fee based on administrative costs. If the inquiry is manifestly unfounded or excessive, we may either charge a fee for providing the information or reject your request. 

Right to rectification 

You have the right to obtain rectification of your personal data if these are inaccurate or misleading. If Scaleup Finance does not agree that the data are inaccurate, however, we are not obliged to correct them, but to add that you as a data subject do not think that the data are correct. 

Right to erasure 

In certain cases, you have the right to obtain erasure of your personal data if Scaleup Finance no longer has a purpose in processing your personal data or you object to the processing of your personal data for the purposes of direct marketing or pursuant to Article 6(1)(f) of the GDPR. If Scaleup Finance can demonstrate overriding legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is necessary for a legal claim to be established, exercised or defended, however, Scaleup Finance is not obliged to erase your personal data.

Right to restriction of processing 

In certain cases, you have the right to obtain restriction of processing of your personal data, e.g. if you contest the accuracy of the personal data collected about you or if you have objected to the processing of your personal data based on legitimate interests pursuant to Article 6(1)(f) of the GDPR. In such an event, Scaleup Finance will only store your personal data until your objection has been considered. If Scaleup Finance lifts the restriction of our processing of your personal data, you will be notified in advance. 

Right to object

On grounds relating to your particular situation, you have the right to object to Scaleup Finance’s processing of your personal data, if the processing is based on legitimate interests, see Article 6(1)(f) of the GDPR. If you object to Scaleup Finance’s processing of your personal data, we are no longer entitled to process your personal data, unless we can demonstrate overriding legitimate grounds for the continued processing that override your interests, rights or freedoms, or the processing is necessary for a legal claim to be established, exercised or defended. You always have the right to object to the processing of your personal data if the processing takes place for the purposes of direct marketing. 

Right to data portability

In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have those data transmitted from one data controller to another data controller. This right applies only when the processing of your personal data is based on a contract pursuant to Article 6(1)(b) of the GDPR or your consent, see Article 6(1)(a) of the GDPR or if the processing is carried out by automated means.

Right not to be subject to a decision based solely on automated processing, including profiling 

Your personal data are not subject to decisions based solely on automated processing, including profiling. 

Right to withdraw your consent

To the extent that we process your personal data based on your consent, you can always withdraw your consent to any future processing. You can withdraw your consent by sending an e-mail to gdpr@scaleup.finance.

Lodge a complaint with a supervisory authority

As a data subject, you can lodge a complaint with Scaleup Finance as data controller if you are not satisfied with the way that we process your personal data. 

You can find our contact information above. 

You can always lodge a complaint with the Danish Data Protection Agency on their website http://www.datatilsynet.dk/, by telephone: +45 33 19 32 00, or by e-mail dt@datatilsynet.dk.

Changes to this privacy policy

Scaleup Finance’s Privacy Policy will be updated on an ongoing basis so that it is always up-to-date. Below you can always find the date of the last updated version of this Privacy Policy.

Last update 3/11/2021