Privacy Policy

ScaleUpMedia takes privacy seriously. This Privacy Policy explains what personal information we collect, how we use it, who we share it with, how we protect it, and what rights you may have.

This Privacy Policy applies to the ScaleUpMedia website, including scaleupmedia.com, the project scoring application, including app.scaleupmedia.com, and any related ScaleUpMedia websites, applications, tools, forms, communications, and services that link to this Privacy Policy.

ScaleUpMedia is operated by ScaleUp Media, LLC, a Florida limited liability company based in Naples, Florida, United States. In this Privacy Policy, "ScaleUpMedia," "ScaleUp Media," "we," "our," and "us" refer to ScaleUp Media, LLC.

1. Who We Are

ScaleUpMedia is a venture studio that provides software development, marketing, growth infrastructure, automation, and venture-partnership services.

For privacy-related questions, you may contact us at:

ScaleUp Media, LLC
8805 Tamiami Trail, Suite 183
Naples, FL 34108
United States

Email: matt@reply.scaleupmedia.com

For purposes of applicable data protection laws, ScaleUp Media, LLC is the controller of personal information collected through our website, applications, and services, except where we process information on behalf of a client under a separate written agreement.

2. Information We Collect

We collect personal information in three main ways:

• Information you provide directly.
• Information collected automatically when you use our website or applications.
• Information received from third parties.

3. Information You Provide Directly

When you interact with ScaleUpMedia, you may provide personal information, including:

3.1 Identity and Contact Information

This may include your name, email address, phone number, company name, organization name, job title, mailing address, and other contact details.

3.2 Project and Business Information

If you use our project scoring application or submit an inquiry, you may provide information about your business, idea, project, budget, timeline, goals, market, technology needs, growth plans, or venture opportunity.

3.3 Engagement Information

If you become a client, we may collect information related to your engagement, including contracts, scopes of work, deliverables, payment schedules, invoices, account details, project documentation, feedback, support requests, and communications with our team.

3.4 Payment and Billing Information

We may collect billing details, invoice information, payment status, transaction confirmations, and related financial records.

Payment method details, such as full credit card numbers or bank account credentials, are typically processed by our payment processors and are not stored directly by ScaleUpMedia.

3.5 Communications

We collect information you provide when you email us, fill out a form, book a call, submit a support request, respond to a survey, join a waitlist, subscribe to updates, or otherwise communicate with us.

4. Information Collected Automatically

When you use our website, applications, or digital services, we may automatically collect certain information, including:

4.1 Usage Data

This may include pages visited, links clicked, features used, session activity, referring pages, time spent on pages, form interactions, and other usage information.

4.2 Device and Technical Data

This may include IP address, browser type, operating system, device type, screen resolution, language settings, referring URLs, access times, and similar technical information.

4.3 Approximate Location Data

We may infer approximate location, such as city, region, or country, from your IP address. We do not collect precise GPS location through the ScaleUpMedia website or project scoring application unless expressly stated in a specific product or service.

4.4 Cookies and Similar Technologies

We use cookies, pixels, tags, scripts, and similar technologies to operate the website, understand usage, improve performance, remember preferences, and support marketing where permitted by law. More detail is provided in the Cookies section below.

5. Information From Third Parties

We may receive information about you from third parties, including:

• Payment processors and financial institutions.
• Analytics providers.
• Advertising and marketing platforms.
• Publicly available sources.
• Business databases.
• Referral partners.
• Clients, contractors, vendors, or partners involved in an engagement.
• Scheduling, CRM, email, or communication tools.

This information may include contact details, company information, transaction confirmations, fraud signals, referral details, marketing attribution data, or publicly available business information.

6. How We Use Personal Information

We use personal information for the purposes described below.

6.1 To Provide and Operate Our Services

We use information to:

• Operate the ScaleUpMedia website and applications.
• Process project scoring requests.
• Evaluate potential projects, partnerships, and engagements.
• Deliver services under signed agreements.
• Manage accounts, contracts, invoices, billing, and payments.
• Communicate about projects, deliverables, timelines, proposals, and support.
• Provide access to tools, applications, or client portals.
• Maintain business records.

6.2 To Operate Project Scoring and AI Tools

We may use information you submit through our project scoring application to generate project scores, recommendations, estimates, internal assessments, or qualification outputs.

Project scoring may use artificial intelligence, automation, proprietary workflows, internal logic, and ScaleUpMedia systems.

Project scoring results are for evaluation purposes only and do not create a binding offer, contract, partnership, or engagement.

6.3 To Improve Our Services

We use information to:

• Analyze usage patterns.
• Improve website and application performance.
• Debug issues.
• Develop new features.
• Improve internal workflows and business operations.
• Evaluate demand for new services.
• Improve project scoring, qualification, and delivery processes.

Where we use data to improve internal systems, we aim to use aggregated, anonymized, or de-identified data where practical. We do not use client venture IP, proprietary client source code, confidential business data, or private client materials to train general AI models without explicit client consent.

6.4 To Communicate With You

We use information to:

• Respond to inquiries.
• Send proposals.
• Schedule calls.
• Provide project updates.
• Send service-related notices.
• Send invoices and payment reminders.
• Provide support.
• Notify you about important changes to our services, policies, or agreements.

6.5 For Marketing and Business Development

Where permitted by law, we may use information to:

• Send newsletters, updates, offers, and educational content.
• Inform you about ScaleUpMedia services that may be relevant to you.
• Invite you to events, webinars, trainings, or programs.
• Measure marketing performance.
• Improve advertising and outreach.

You may opt out of marketing emails at any time by using the unsubscribe link in the email or by contacting us at matt@reply.scaleupmedia.com.

6.6 For Security, Legal, and Compliance Purposes

We use information to:

• Protect our website, applications, systems, and users.
• Detect fraud, abuse, unauthorized access, and security incidents.
• Enforce our Terms of Service and agreements.
• Comply with applicable laws, regulations, subpoenas, court orders, or legal processes.
• Protect the rights, property, and safety of ScaleUpMedia, our clients, our users, and others.
• Maintain records required for tax, accounting, legal, or compliance purposes.

7. Legal Bases for Processing

If you are located in the European Economic Area, United Kingdom, or Switzerland, we process your personal information under one or more of the following legal bases:

7.1 Contract

We process information when necessary to perform a contract with you or to take steps before entering into a contract, including project evaluation, proposals, engagement delivery, billing, and support.

7.2 Consent

We process information based on consent when required, including for certain marketing communications, optional cookies, or specific data uses where consent is legally required.

7.3 Legitimate Interests

We process information where necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. These interests may include improving services, securing systems, business development, analytics, fraud prevention, and client relationship management.

7.4 Legal Obligation

We process information where necessary to comply with legal obligations, including tax, accounting, regulatory, legal process, and recordkeeping requirements.

8. How We Share Personal Information

We do not sell personal information.

We may share personal information in the following circumstances.

8.1 Service Providers

We share information with third-party service providers that help us operate our business, including hosting providers, payment processors, analytics providers, email providers, CRM systems, AI infrastructure providers, project management tools, security providers, and communication platforms.

These providers are authorized to use personal information only as necessary to provide services to us or as otherwise permitted by law.

8.2 Engagement Partners

For certain client engagements, including Venture Partnership engagements, we may share information with co-operating partners, contractors, developers, designers, marketers, advisors, or other team members involved in delivering the engagement.

The scope of this sharing is governed by the applicable Engagement Contract and related agreements.

8.3 Legal and Compliance Disclosures

We may disclose information if required by law, regulation, subpoena, court order, government request, or legal process.

We may also disclose information if we believe disclosure is necessary to protect rights, property, safety, security, enforce agreements, investigate fraud, prevent abuse, or respond to a legal claim.

8.4 Business Transfers

If ScaleUpMedia is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar transaction, personal information may be transferred as part of that transaction.

8.5 With Your Consent

We may share information for other purposes with your consent or at your direction.

9. What We Do Not Do

ScaleUpMedia does not:

• Sell personal information.
• Rent or trade personal information to third parties.
• Use client venture IP, proprietary source code, confidential business data, or private client materials to train general AI models without explicit client consent.
• Share client-specific project details across unrelated clients.
• Use children's information for behavioral advertising.
• Market directly to children through ScaleUpMedia children-directed products.

10. Third-Party Services We Use

We use third-party tools and service providers to operate our website, applications, communications, payments, analytics, AI systems, and business operations.

These may include:

10.1 Hosting and Infrastructure

We may use hosting and infrastructure providers such as Vercel, cloud hosting platforms, database providers, security providers, and content delivery networks.

10.2 Payment Processing

We may use Stripe or similar payment processors to process payments, subscriptions, invoices, billing details, fraud checks, and transaction records.

10.3 Analytics

We may use analytics tools such as Google Analytics or similar platforms to understand website traffic, usage patterns, and performance.

10.4 Communications and CRM

We may use email, CRM, scheduling, support, and communication tools to manage inquiries, newsletters, client communications, project updates, and business development.

10.5 AI Infrastructure

We may use AI infrastructure providers, including providers such as Anthropic, OpenAI, or similar model and infrastructure providers, to support project scoring, automation, internal workflows, and service delivery.

10.6 Project Delivery Tools

We may use project management tools, document tools, code repositories, collaboration platforms, design tools, cloud storage, and communication systems to deliver client work.

Each third-party provider operates under its own privacy policy, security practices, and terms.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to operate our website, improve performance, understand usage, remember preferences, and support marketing where permitted.

11.1 Types of Cookies We Use

We may use:

• Essential cookies: Required for website and application functionality, authentication, security, and session management.
• Analytics cookies: Help us understand how visitors use our website and applications.
• Preference cookies: Remember user preferences and settings.
• Marketing cookies: Help measure campaigns, improve advertising, and understand attribution where permitted by law.

11.2 Managing Cookies

You can control cookies through your browser settings. Disabling certain cookies may affect website or application functionality.

Where required by law, we provide cookie consent options that allow users to accept, reject, or manage non-essential cookies.

12. Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Our typical retention practices include:

• Engagement records: Retained for the duration of the engagement and for a reasonable period afterward for legal, tax, accounting, and business record purposes.
• Contracts, invoices, and payment records: Retained as required for tax, accounting, legal, and compliance purposes.
• Project scoring submissions: Retained for a reasonable period to evaluate potential engagements, improve scoring workflows, and maintain business records, unless deletion is requested and no legal exception applies.
• Marketing data: Retained until you unsubscribe, request deletion, or become inactive for a reasonable period.
• Analytics data: Retained according to the settings of our analytics providers and our internal retention practices.
• Client communications: Retained as needed for project delivery, legal compliance, quality assurance, and business records.

When information is no longer needed, we delete, anonymize, or de-identify it where practical.

13. Data Security

We use commercially reasonable technical, administrative, and organizational measures to protect personal information against unauthorized access, misuse, loss, disclosure, alteration, or destruction.

These measures may include:

• Encryption in transit.
• Encryption at rest where applicable.
• Access controls.
• Authentication controls.
• Limited access based on business need.
• Vendor review.
• Secure infrastructure practices.
• Monitoring and incident response processes.
• Internal confidentiality obligations.

No system is completely secure. We cannot guarantee absolute security, but we work to maintain commercially reasonable safeguards appropriate to the nature of the information we process.

14. International Data Transfers

ScaleUpMedia is based in the United States.

If you access our website, applications, or services from outside the United States, your information may be processed in the United States or other countries where we or our service providers operate.

These countries may have data protection laws that differ from the laws of your country.

Where required by applicable law, we rely on appropriate transfer mechanisms, such as Standard Contractual Clauses, adequacy decisions, data processing agreements, or other legally recognized safeguards.

15. Your Privacy Rights

Depending on where you live, you may have certain rights regarding your personal information.

These rights may include:

• Access: Request a copy of personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of personal information, subject to legal exceptions.
• Portability: Request a copy of your information in a structured, commonly used format.
• Objection: Object to certain processing activities.
• Restriction: Request that we restrict certain processing.
• Withdrawal of consent: Withdraw consent where processing is based on consent.
• Opt out of marketing: Unsubscribe from marketing communications.

16. EEA, UK, and Switzerland Privacy Rights

If you are located in the European Economic Area, United Kingdom, or Switzerland, you may have additional rights under applicable data protection law, including the right to lodge a complaint with your local data protection authority.

You also have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects, unless permitted by law.

ScaleUpMedia's project scoring tool may use automated processing to generate non-binding project assessments, estimates, or recommendations. These outputs are for evaluation purposes only and do not create legal, contractual, or similarly significant effects unless separately reviewed and agreed to by ScaleUpMedia and the user through a signed agreement.

17. California Privacy Rights

If you are a California resident, you may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act.

These rights may include:

• The right to know what personal information we collect, use, disclose, or share.
• The right to request access to personal information.
• The right to request deletion of personal information.
• The right to request correction of inaccurate personal information.
• The right to opt out of the sale or sharing of personal information.
• The right to limit the use of sensitive personal information, where applicable.
• The right not to be discriminated against for exercising privacy rights.

ScaleUpMedia does not sell personal information.

If we use advertising or analytics technologies that may be considered "sharing" under California law, we will provide applicable opt-out rights where legally required.

18. Other US State Privacy Rights

Residents of certain US states may have additional privacy rights under applicable state privacy laws, including rights to access, correct, delete, obtain a copy of personal information, opt out of certain targeted advertising, opt out of certain profiling, or opt out of certain data sales.

To exercise these rights, contact us using the information below.

19. How to Exercise Your Rights

To exercise any privacy rights, contact us at:

Email: matt@reply.scaleupmedia.com

We may need to verify your identity before processing certain requests. We will respond within the timeframe required by applicable law.

We may deny or limit a request where permitted by law, including where we must retain information for legal, security, fraud prevention, tax, accounting, contractual, or legitimate business purposes.

20. Children's Privacy

The ScaleUpMedia website and project scoring application are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13 through scaleupmedia.com or app.scaleupmedia.com.

If we learn that we have collected personal information from a child under 13 without appropriate consent, we will take reasonable steps to delete that information.

21. Children-Directed Products in the ScaleUpMedia Portfolio

Certain products or ventures operated, developed, or supported by ScaleUpMedia may be designed for use by children, including educational products such as GRASP.

Those products may operate under separate product-specific privacy policies, consent flows, and data practices. If a product-specific privacy policy conflicts with this Privacy Policy for that product, the product-specific privacy policy controls for that product.

22. Parent-Controlled Child Accounts

For children-directed products that use parent-controlled accounts, a parent or legal guardian may create and manage a child profile or sub-account.

In that model:

• The parent or guardian creates the primary account.
• The parent or guardian provides information about the child.
• The parent or guardian controls settings, permissions, and access.
• The child does not create an independent account directly with ScaleUpMedia unless expressly permitted under the product-specific privacy policy and applicable law.
• The parent or guardian may request access, correction, export, or deletion of the child's information.

23. Information Collected for Child Profiles

For children-directed products, we may collect limited information provided by a parent or guardian, such as:

• Child first name or display name.
• Age, grade level, or learning stage.
• Learning preferences.
• Curriculum level.
• Progress data.
• Lesson activity.
• Scores or performance data.
• Time on task.
• Parent-controlled account settings.

Unless a product-specific privacy policy states otherwise, we do not knowingly collect a child's email address, phone number, precise location, photographs, or other unnecessary personal information through child profiles.

24. How Child Profile Information Is Used

Child profile information is used only as reasonably necessary to:

• Provide the educational or child-directed product.
• Match content to the child's learning level.
• Track progress for parent or guardian review.
• Improve the experience within that specific product.
• Maintain safety, security, and compliance.
• Provide support to the parent or guardian.

We do not use child profile information for behavioral advertising, sale to third parties, or training general AI models.

25. Parental Rights

Parents and guardians may request to:

• Review information associated with a child profile.
• Correct inaccurate information.
• Delete a child profile.
• Export child profile information where available.
• Refuse further collection or use of a child's information.

To make a request, contact us at matt@reply.scaleupmedia.com or through the privacy contact listed in the product-specific privacy policy.

26. Links to Third-Party Websites

Our website, applications, communications, or services may contain links to third-party websites, services, tools, or platforms.

We are not responsible for the privacy practices, security practices, content, or policies of third parties. You should review the privacy policies of third-party services before providing information to them.

27. Do Not Track

Some browsers offer "Do Not Track" signals. There is no uniform industry standard for responding to these signals, and our website may not respond to them.

Where legally required, we honor applicable opt-out preference signals, such as Global Privacy Control, in accordance with applicable law and technical feasibility.

28. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we update this Privacy Policy, we will revise the "Last updated" date at the top of this page.

If we make material changes, we may provide additional notice, such as posting a prominent notice on our website or contacting affected individuals through the contact information we have on file.

Your continued use of our website, applications, or services after an updated Privacy Policy is posted means you acknowledge the updated policy.

30. Cookies, Advertising, and Opt-Out Rights

ScaleUpMedia may use cookies, pixels, tags, scripts, and similar technologies to operate the website, analyze usage, improve performance, remember preferences, measure marketing campaigns, and support advertising or retargeting where permitted by law.

More detail is provided in our Cookie Policy.

Where required by law, users may have the right to opt out of certain analytics, advertising, targeted advertising, sale, or sharing activities. ScaleUpMedia does not sell personal information for money. However, some advertising or analytics technologies may be considered "sharing" or "targeted advertising" under certain privacy laws.

Where legally required, ScaleUpMedia provides a method to opt out of such processing, including through our Cookie Policy, cookie preference tools, or a Do Not Sell or Share My Personal Information page.

31. Global Privacy Control and Opt-Out Preference Signals

Where required by applicable law, ScaleUpMedia honors recognized browser-based opt-out preference signals, such as Global Privacy Control, to the extent they are technically detectable and legally applicable to our website.

If your browser or extension sends a valid opt-out preference signal, we will treat that signal as a request to opt out of applicable sale, sharing, or targeted advertising activities for that browser or device, where required by law.

Because these signals are browser and device specific, you may need to enable them separately on each browser or device you use.

32. Sensitive Personal Information

ScaleUpMedia does not intentionally collect sensitive personal information through the general website, project scoring application, or standard intake forms unless it is necessary for a specific engagement and governed by an applicable written agreement.

Sensitive personal information may include protected health information, medical information, precise geolocation, financial account data, government identification numbers, biometric information, children's information, racial or ethnic origin, religious beliefs, union membership, sexual orientation, or other information treated as sensitive under applicable law.

You should not submit sensitive personal information through general website forms, project scoring forms, or email unless ScaleUpMedia has expressly requested it and appropriate contractual, privacy, and security terms are in place.

33. Data Processing Addendum and Subprocessors

For certain client engagements, ScaleUpMedia may process personal information on behalf of a client. In those cases, the applicable Engagement Contract, Data Processing Addendum, Business Associate Agreement, security addendum, or other written agreement governs ScaleUpMedia's role and obligations.

ScaleUpMedia may use subprocessors and third-party providers to deliver hosting, infrastructure, communications, analytics, payment processing, AI infrastructure, project management, source control, and other services.

A current list of key subprocessors may be made available through our Subprocessors page or upon request.

34. Contact Us

For questions about this Privacy Policy, to exercise privacy rights, or to raise concerns about how we handle personal information, contact:

ScaleUp Media, LLC
8805 Tamiami Trail, Suite 183
Naples, FL 34108
United States

Email: matt@reply.scaleupmedia.com