Competing Against Luck: The Story of Innovation and Customer Choice

What information do we collect?

Scalabl receives and stores (a) information that you provide to us, (b) information obtained from third parties, and (c) information collected by our systems, as described below:

1. Information provided to us by the User

   By entering the Course, you agree to provide Scalabl with personal information regarding your identity, including but not limited to your first and last name, address, telephone number, e-mail address, date of birth, and nationality ("Personal Information").

   Additionally, during the Course, you may provide us with opinions and comments (hereinafter, the "Opinions"). In this case, you accept and agree that all Feedback you submit to us will be published on the Website or on other websites and/or applications with whom Scalabl has contractual relationships. In such a case, we inform you that, eventually, you may be identified with your full name, photo, professional profile, comment, and nationality. By giving us your opinion or uploading real photos through the Course and/or the Website, you are assigning to Scalabl all property rights on such photos and Opinions. We remind you that you may delete your feedback by following the procedure detailed below in point 6. How can I access, delete and/or update the Collected Information?

2. Information provided by third parties

   To the extent permitted by applicable law, Scalabl may also obtain Personal Information from you and aggregate it with Personal Information provided to us by third parties, whether group companies, business partners, and/or other independent third-party sources, such as public databases, information collected during a telephone conversation and/or through interactive applications. You should note that all information we collect about each User may only be used for the purposes set out in point 2. Any Personal Information obtained by Scalabl by the means described herein will be treated under the provisions of this Privacy Policy.

   As already established in the previous points, Scalabl will not provide Users' data to third parties. Should it wish to do so, you will be informed in advance and your consent will be requested.

3. Information collected by our systems. Cookies Policy. Links to other sites. Geolocation Services

   Scalabl may collect and process information about your visits to our Web Site. This information may be used to improve the content of the Website and/or the Course. For these purposes, we may set "cookies," which are small pieces of text that are used to retain information in web browsers and are stored on the hard drive of your device. These cookies may be used by Scalabl or by third parties.

   In addition, through cookies or a geolocation service based on the IP of your connection or GPS, Scalabl will be able to access your location information to provide you with a better service from the Website.

   We have content on the Website that links to third-party sites or services. When a third-party service is enabled, you authorize us to connect and access other information that is available under our agreement with the service provider. However, Scalabl does not receive or store passwords from any of these third-party services.

   In this regard, as data processors, we have contracted with the following service providers, who have committed to comply with the applicable data protection regulations at the time of contracting:

   • Teachable Inc

     , 16 W. 22nd Street, 6th Floor, New York, New York 10010, which provides web course creation services. The privacy policy and other legal aspects of the company can be consulted at the following link: https://teachable.com/privacy-policy

   • Facebook Ireland Limited

     (identified by the trademarks Facebook, Messenger, Instagram, and/or WhatsApp), VAT registered number IE9692928F and domiciled at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy and other legal aspects of said company can be consulted at the following link: https://www.facebook.com/about/privacy/update

   • LinkedIn Ireland Unlimited Company

     , Wilton Place, Dublin 2, Ireland. The privacy policy and other legal aspects of this company can be viewed at the following link: https://www.linkedin.com/legal/privacy-policy

What do we use the information we collect for?

Scalabl uses your Personal Information for the following purposes:

1. To provide the Course and its related services.
2. To prevent or address any errors, technical or security problems, or fraud on the Website.
3. To analyze and monitor usage, trends, and other activities of Users.
4. To comply with the requirements of applicable laws, regulations, and legal procedures.
5. To communicate with the User in response to User requests, comments, and questions.
6. To develop and provide search, training, and productivity tools and additional features.
7. To send emails and other communications regarding new Courses and/or Website features, as well as promotional communications or other news about Scalabl.
8. For billing, account management, and other administrative purposes. Please be advised that Scalabl may need to contact you for billing, account management, and other similar reasons.

Why do we need express consent?

In compliance with the requirements of the European Regulation 679/2016, of April 27, on Personal Data Protection, by the Organic Law 3/2018 on Personal Data Protection and guarantee of digital rights, and by the Argentine law 25.326, on Personal Data Protection, and following the provisions of our internal policies, we need your personal data in order to identify you and provide you with the Course.

With such action(s), you are freely and unequivocally declaring that you agree that Scalabl treats your data according to the purposes mentioned in the previous sections.

The User guarantees that the personal data provided to Scalabl are truthful and is responsible for communicating to Scalabl any modification thereof.

The User's acceptance that his/her data will be processed for the purposes referred to in this Privacy Policy is always revocable, without retroactive effects, under the provisions of current legislation.

With whom is the Personal Information collected shared?

This section describes with whom Scalabl may share and disclose Information:

1. Group companies: Scalabl may share information with any of its controlled, controlling, and related companies.
2. Corporate reorganization: If from time to time, Scalabl is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our corporate assets or interests, financing, public offering, acquisition of all or part of our business, or similar transaction or proceeding, some or all of the Personal Information may be shared or transferred, subject to standard confidentiality agreements.
3. With competition authorities: only in case of receiving requests of a judicial nature in accordance with the requirements of applicable laws, regulations and legal procedures.
4. Between Users: the Course and/or the Web Site allows collaborative work between Users, allowing each one to eventually issue Opinions during the Course.

Where do we store and how do we protect the information we collect?

All Personal Information is collected and stored on servers physically located in the United States, European Community, and/or Argentina. By accepting the Privacy Policy, you agree that Scalabl may transfer your Personal Information to any country in the world. In any case, Scalabl is committed to guaranteeing that the legally required standards for the protection and safeguarding of your Personal Information are met, through the signing of agreements or conventions whose purpose is the privacy of your Personal Information.

In order to guarantee the security of our Website, we have integrated a security system that allows us to maintain the confidentiality and integrity of the data of our Users that have been sent or collected through the means mentioned in the first point.

Thus, Scalabl maintains the security levels of data protection required by the new legislation and regulations referred to throughout the text and has provided on the Website all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of the data provided by the User through the Website.

Also, as a User of our Website and/or the Course you understand, accept, and understand that security measures on the Internet are not impregnable and that, therefore, you are obliged to adopt the necessary security measures that allow you to trust the veracity of the Website in which you are entering your data. We will also do our best to ensure the privacy and security of your identification data at all times, always using the utmost diligence and implementing the necessary measures.

Thus, we inform you that you will be solely responsible for the security measures that you implement concerning the protection of your data, with which, Scalabl is not responsible for situations where the User has not implemented the corresponding security measures, nor for their consequences, as well as for causes or damages caused by third parties outside Scalabl, including fortuitous cases and/or force majeure.

In accordance with the aforementioned, Scalabl cannot guarantee that unauthorized third parties may have knowledge of the type, conditions, characteristics, and circumstances of the use that the Users make of the Course.

What data do we retain after your User account is deactivated?

If you cease to be a User, we inform you that Scalabl will only retain your Personal Information for the period necessary to comply with the requirements of applicable law.

What are your rights when you provide us with your data?

The applicable legislation and regulations have implemented a series of legal guarantees that allow the User to exercise rights and actions related to the processing of his or her data.

Scalabl offers you this legal guarantee, with which, at any time and/or when you consider it convenient, you can make use of your rights of access, rectification, suppression, opposition, portability, and oblivion by writing to the contact email that we have enabled for this purpose: [email protected], attaching a copy of your passport or your ID card (holder of the data) and indicating in the subject expressly the request you wish to make: access, rectification, suppression, opposition, portability, oblivion and limitation of processing.

Notwithstanding the above, it is important that as a User you keep in mind that the information you have shared, by any means, may continue to be visible and that Scalabl is exonerated from any responsibility in relation to the elimination of this information.

Likewise, Scalabl does not control the renewal system of third party search mechanisms, which may contain certain public profile information that has already been deleted by Scalabl but that is still visible on the Internet due to the rebroadcast of the same, in which case, we recommend that you contact those responsible for those platforms and/or websites to request its deletion or the exercise of the right to oblivion.

We explain briefly what each of the rights you can exercise consists of:

• ✓ Right of access:

  by exercising this right, you will be able to know what processing is carried out on your personal data by Scalabl: its purpose, origin, or possible transfer to third parties.

• ✓ Right to erasure (or right to be forgotten):

  you may request the deletion of your personal data, without undue delay, when any of the cases contemplated occur. For example, unlawful data processing, or when the purpose for which the data was processed or collected has disappeared. However, there are several exceptions in which this right does not apply. For example, when the right to freedom of expression and information must prevail.

• ✓ Right of opposition:

  through this right you may oppose the processing of your personal data: (i) when, for reasons related to your personal situation, the processing of your data must cease unless a legitimate interest is proven, i.e. necessary for the exercise or defense of claims, or, (ii) when the processing is for the purpose of direct marketing.

• ✓ Right to limit processing:

  you may ask us to restrict the processing of your data (i) when the accuracy of the data is contested, while we verify such contestation, (ii) when the processing is unlawful, but you object to the deletion of your data and request the restriction of the processing instead, (iii) when you are the one who needs them in case of a claim (iv) and even when you have objected to the processing of your data for the performance of a mission in the public interest or for the satisfaction of a legitimate interest, which must be verified. In these cases, we will only keep them for the exercise or defense of claims.

• ✓ Right of portability:

  you may request the portability of your data in a structured, commonly used and machine-readable format, so that it can be transmitted to another entity, provided that this is technically possible.

To exercise any of these rights, you must send an email to the mailbox [email protected], after which we will contact you to validate your identity and resolve your request.

Also, at any time, you may withdraw your consent without affecting the lawfulness of the processing already carried out, by sending your request to the same address indicated in the previous paragraph. In this case, it is also necessary to attach a copy of your National Identity Card or an equivalent document proving your identity to your request.

Social Media Policy

Scalabl has corporate profiles and/or private groups in the social networks Facebook, Instagram, LinkedIn, Twitter, YouTube, WhatsApp, Telegram, Pinterest, TikTok, and Clubhouse (hereinafter, the "Social Networks"). Thus, according to the provisions of the European Data Protection Regulation 679/2016 of April 27, 2016, and the Argentine Personal Data Protection Law, Law No. 25,326, Scalabl is "Responsible for the processing of your data" on the grounds of the existence of such profiles on these social networks and the fact that you follow us and we can follow you.

On the other hand, we inform you that we will use social networks as a channel of interaction between Users and Scalabl.

However, we also let you know that there is no link between Scalabl and such social networks, so you will accept their policy of use and conditions once you access them and/or accept their notices and/or terms and conditions in the registration procedure, and Scalabl will not be responsible for the use or treatment of your data that is made outside the strict relationship and provision of services indicated in this Privacy Policy.

Integration with the rest of the legal texts

This Privacy Policy is supplemented by the Terms and Conditions of Use and the Cookie Policy associated with this Web Site.