Privacy Notice

Scallor Inc. is an Ontario corporation at 2 Robert Speck Pkwy, Suite 750, Mississauga, ON L4Z 1H8, Canada. References to "we", "us" or "our" mean Scallor. References to "you" mean a visitor, a prospective customer, or an authorised user of a customer account.

Scallor is accountable for the personal information under its control, including information transferred to the service providers and subprocessors in Section 5. We have appointed a Privacy Officer responsible for our compliance with this notice and with applicable privacy law.

Privacy Officer: Sulakshana Arora, [email protected], 2 Robert Speck Pkwy, Suite 750, Mississauga, ON L4Z 1H8, Canada. We answer privacy enquiries, access requests and complaints through the same office.

When we are a controller and when we are a processor

For the personal information Scallor handles as an organisation, described in Section 2, Scallor is the controller: it determines the purposes and means of the processing and is directly accountable for it.

For the customer content that a customer and its authorised users put into Scallor, the customer is the controller and Scallor is the processor: it processes that content only on the customer's documented instructions and for the purposes set out in the customer agreement and its Data Processing Addendum. Where a customer itself processes that content on behalf of its own client, the customer is a processor, that client is the controller, and Scallor is a subprocessor. Under United States state privacy law, "controller" includes the equivalent term "business" and "processor" includes "service provider".

Scallor is a multi-tenant platform. Each customer account is logically separated from every other account by row-level security, which is designed so that one customer's data is not accessible to another and is not combined with another account's data.

Where an individual asks Scallor to access, correct or delete personal information that sits within a customer's account, Scallor refers that request to the relevant customer and supports the customer in responding, unless the customer agreement or the law directs otherwise. Requests about the personal information Scallor handles as an organisation are answered by Scallor directly under Section 8.

We collect only what we need for the purposes in Section 3.

• Account and profile information: name, work email address, job title, organisation, account role, and authentication credentials for administrators and authorised users of a customer account.
• Customer content: the data, documents, messages and other content that a customer and its users create or upload, which may contain personal information about the customer's own personnel, clients or contacts. This content belongs to the customer and is handled on the customer's instructions.
• Information you provide: when you apply for early access or contact us, the details you submit, such as name, work email, company and role-related context.
• Contact form: when you use the contact form at the bottom of the site, your name, work email, your message, and the page you sent it from. We use this solely to respond to your enquiry. It does not add you to any mailing list.
• Product feedback signals: in-product feedback such as a thumbs up or thumbs down on a Pulse answer, and the acceptance or decline of a Pulse suggestion, together with the interaction context needed to make that signal meaningful.
• Billing information: the account, contract and billing-contact details needed to administer a subscription. Payment-card data, where applicable, is handled by our payment provider and is not stored by Scallor.
• Strictly necessary cookies: small pieces of data required to run the site, covering security, basic routing, and remembering your cookie choice. These are always on.
• Analytics, only if you opt in: aggregated, non-identifying information about how the site is used, covering pages viewed, approximate location at country level and device type, via Google Analytics and Microsoft Clarity. Clarity records heatmaps and session replay. This is captured using first-party and third-party cookies. We do not build a personal profile.
• Marketing, only if you opt in: measurement of how outbound campaigns perform. Off by default.
• Server logs: our hosting provider keeps standard request logs, covering IP address, timestamp, page requested and user agent, for security and abuse prevention. These are kept on a short rolling window.

Scallor does not seek to collect sensitive personal information, and Pulse is not designed for it. Because customer content is free-form, it may occasionally include sensitive categories that a customer or its users choose to enter. That content is handled on the customer's instructions and under the controls in Section 10.

• To create and administer accounts, authenticate users, deliver Scallor and Pulse, and respond to requests.
• To run, secure, support and improve each customer's own use of the Service, including by using product feedback signals as Section 6 describes.
• To improve the Service generally, using only aggregated and de-identified signals that do not identify any customer or individual.
• To detect, prevent and respond to fraud, abuse, security incidents and technical faults, and to maintain audit logs.
• To run, secure and improve the website, and to understand in aggregate what content is useful, only where analytics consent has been given.
• To send account, security, billing and other service messages, and, with your consent where required, product and marketing messages that you can decline at any time.
• To administer contracts, enforce our terms, comply with law, and establish, exercise or defend legal claims.

Service messages about your account, security and billing are part of the Service and are sent while an account is active. Marketing messages are separate and are sent only where you have opted in, consistent with Canada's Anti-Spam Legislation. You can withdraw marketing consent at any time.

We do not sell your personal information. We do not share it with third parties for their own marketing purposes.

Consent. We rely on your consent to collect, use and disclose personal information, except where the law permits or requires us to act without it. For routine operational information needed to deliver the Service, consent is implied by your use of the Service after being given this notice. For sensitive information, for marketing, and for any use beyond the purpose the information was collected for, we rely on express consent. You can withdraw consent at any time, subject to legal and contractual limits and to reasonable notice. Withdrawing consent may mean we can no longer provide part or all of the Service, and we will tell you if that is the case before you decide.

We use cookies for three purposes: strictly necessary, analytics (opt-in) and marketing (opt-in). Analytics, marketing and profiling cookies are off by default for every visitor, and we obtain your prior consent before any non-essential cookie is set. You can review and change your choice at any time via the Cookie settings control. Necessary cookies cannot be turned off because the site cannot function without them.

Full detail on the cookies we use and how to manage them is in our Cookie Policy.

We use a small number of vetted vendors that process information strictly to deliver the website and the Service. Each is engaged under that vendor's own standard data processing agreement, which limits it to processing personal information on Scallor's instructions and requires it to protect that information. Scallor has not entered into any bespoke or negotiated data processing agreement with a subprocessor. Scallor remains accountable for personal information transferred to them.

• Hosting & database: our infrastructure runs on AWS US East (N. Virginia), with Vercel providing application hosting and Supabase providing database hosting and authentication.
• Website delivery: this marketing site is hosted by Hostinger, with Cloudflare providing DNS and edge delivery. Both process request metadata and IP addresses in transit. Neither holds product data.
• Email: Resend handles delivery of transactional and contact-form emails.
• Enquiry tracking: HubSpot, hosted in Canada, stores enquiries and estimates submitted through forms and resources on this site so our team can respond and track follow-up.
• Analytics: Google Analytics (Google LLC) measures aggregated site usage. See Google's Privacy Policy.
• Behavioural analytics: Microsoft Clarity records heatmaps and session replay to help us improve the site, and is administered under our Microsoft Advertising account. It loads only if you opt in to analytics cookies, and you can withdraw that consent at any time from the cookie settings control. See the Microsoft Privacy Statement.
• AI processing: product AI features run on OpenAI and Anthropic. Section 6 sets out how.
• Collaboration, recording and operations: we also use Google Workspace, Zoom, Fathom, Jotform, GitHub, Sentry, Snyk and Stripe to run delivery, support, contract execution, engineering and billing. Session recording is covered in Section 6.

The authoritative public list of subprocessors, with each vendor's function and processing location, is maintained on our Trust & Compliance Centre. For a customer under a signed agreement, Annex 3 of the Data Processing Addendum is the controlling list.

If Scallor adds or changes a subprocessor that performs a materially different function, we update this notice and the Trust & Compliance Centre and, where a customer agreement or the law requires, give affected customers advance notice and a right to object.

Four further providers support this marketing website or Scallor's own sales activity only and are not subprocessors for the Service: Google Analytics and Microsoft Clarity (analytics and session replay, loading only after analytics consent), Hostinger (marketing-site hosting, server access logs only) and Apollo.io (sales prospecting, processing prospect and lead contact details). None of the four processes customer content.

Pulse is Scallor's AI assistant. It helps authorised users work with their own account's data. Scallor operates no model of its own. Pulse is powered by third-party large-language-model providers, OpenAI and Anthropic, accessed through their APIs. Both are subprocessors, and each is engaged under its standard API terms.

No training on your data. Scallor does not use customer data to train or fine-tune any machine-learning model, and does not permit its AI subprocessors to use customer data to train or fine-tune any model. Content sent to an AI subprocessor is processed under terms that exclude use of the data for provider model training.

What the AI providers retain. Scallor has no bespoke, enterprise or zero-retention arrangement with either provider, and has not elected a reduced-retention option. Under each provider's published policy, content sent to the API is retained for up to 30 days for abuse monitoring and is then deleted, except where the provider retains content for longer to enforce its usage policy or where the law requires. These terms are set by the providers and are outside Scallor's direct control. We monitor them and will update this notice and, where required, notify affected customers if a provider materially changes them.

How content reaches them. Content sent to an AI subprocessor is encrypted in transit. Scallor does not redact or remove personal information from content before it is processed. Redaction and tokenisation are items on our roadmap, not current controls, and this notice does not represent otherwise.

Feedback signals. A feedback signal is a product signal. It is not used to train any model. Where a user saves specific prompts or preferences within the platform, Pulse draws on them as guidance so its suggestions align with the guidelines that customer has set. These saved prompts and preferences stay within that customer's account and are not used to train any model.

Aggregated improvement, kept separate. Only aggregated and de-identified signals, which do not identify any customer or individual, inform general improvement of the Service. Because each account is separated by row-level security, one customer's content is not used to improve, inform or influence another customer's experience.

Human in the loop. Pulse supports human decisions. It does not make decisions about you based solely on automated processing. Pulse outputs are decision support for a customer's authorised users, who remain responsible for reviewing them and for the decisions they make. Outputs are generated probabilistically and may be inaccurate or incomplete. Where a decision would be based exclusively on automated processing, we will provide the notice and explanation that Quebec's Law 25 requires. We disclose that Pulse provides AI assistance in any event.

Session recording. Advisory, onboarding and delivery sessions are recorded or transcribed only where a customer's Order Form provides for it or the customer agrees in writing. We announce a recording at the start of each session and obtain the participants' agreement before it begins. Where recording is enabled, Fathom processes the recording and transcript. Cloud recording is not enabled on our Zoom account, so Zoom retains meeting metadata only. We do not enable recording with a provider unless that provider's model-improvement setting is disabled for Scallor's account, or the provider has confirmed in writing that session recordings, transcripts and derived data are excluded from training or improving any model.

We keep personal information only as long as we need it for the purposes above, or as required by law or a legal hold.

Website and prospect information

• Contact-form enquiries: up to 12 months after our last exchange with you.
• Application records: up to 24 months after last contact.
• Aggregated analytics, if opted in: up to 14 months.
• Server logs: a short rolling window set by our host.

Customer content, on termination of a customer agreement

• Export window: 30 days after termination, during which the customer may export its data.
• Deletion from production: customer content is deleted from production systems within 30 days of termination, running concurrently with the export window.
• Back-ups: customer content may remain in routine back-ups for no more than 35 days after deletion from production, which is up to 65 days after termination, after which it is overwritten or deleted in the ordinary course. Back-up copies stay subject to the confidentiality and security obligations of the customer agreement until deleted.
• AI subprocessors: content is retained under the providers' applicable terms, described in Section 6.
• De-identified audit metadata: retained for up to two years for security, audit and legal-compliance purposes, then purged, unless a longer period is required by law or a legal hold. It contains no customer content and does not identify the customer or any individual.
• Aggregated and de-identified data: retained and used after termination, and not deleted. It does not identify any customer or individual.

Account, billing and enquiry information that Scallor holds as an organisation is kept for as long as needed to administer the relationship and to meet legal, tax and accounting obligations, and is then deleted or de-identified. Where a customer agreement states a specific period, that agreement governs.

Subject to the law that applies to you, you have rights over your personal information. You can ask us to access or correct the personal information we hold about you, withdraw consent to a use, and opt out of marketing messages at any time using the unsubscribe link or by contacting the Privacy Officer.

To exercise a right, email [email protected]. We will verify your identity, respond within the time the law requires, and explain any refusal. Where a request concerns personal information within a customer's account, Section 1 applies and we route the request to the relevant customer.

Canada (PIPEDA + Quebec Law 25)

Under PIPEDA and applicable provincial law you have the right to access and correct your personal information and to withdraw consent for its use, and to complain to the Office of the Privacy Commissioner of Canada. Quebec's Law 25 may apply to you by reference to where you and your organisation are, regardless of where Scallor hosts data, and where it applies you may also complain to the Commission d'accès à l'information du Québec. The individual responsible for the protection of personal information at Scallor is the Privacy Officer named in Section 1.

Where Law 25 applies, Scallor will report a confidentiality incident presenting a risk of serious injury, in respect of personal information Scallor handles as an organisation, to the Commission d'accès à l'information and to affected individuals. For personal information inside a customer's account, notification to a regulator or to individuals is the customer's responsibility and Scallor assists as the Data Processing Addendum provides.

A French-language version of this notice will be made available to individuals in Quebec. We are confirming the timing with Quebec-qualified counsel.

United States (CCPA / CPRA)

If you are a California resident, you have the right to know what personal information we have about you, request a copy, ask us to delete it, and ask us to correct inaccuracies. We do not sell or share personal information for cross-context behavioural advertising, and we do not process sensitive personal information for purposes other than those the CCPA allows. To exercise any of these rights, email [email protected]. We will not discriminate against you for exercising your rights. If you have an authorised agent acting on your behalf, please include written authorisation with your request. Where a customer is subject to the CCPA in respect of personal information in its customer content, Scallor acts as a service provider under the Data Processing Addendum.

Outside Canada and the United States

Scallor is offered in Canada and the United States, and this notice is written under Canadian law. If you are elsewhere, additional privacy laws and additional rights may apply to you under the law of your own jurisdiction, and this notice does not purport to describe them. You may contact your local supervisory authority, and we will honour applicable local requirements.

Scallor has not adopted a transfer mechanism under the General Data Protection Regulation (EU) 2016/679, the UK GDPR or the Data Protection Act 2018 (UK), and its standard customer terms do not address those laws. A customer that needs terms for them must agree them with us in writing, and should not submit personal information subject to them until it has.

This section is the master statement of where Scallor processes and stores personal information. Customer agreements refer to this section rather than restating it.

The Service is hosted on Amazon Web Services in the US East (Northern Virginia) region, with back-up and disaster-recovery copies that may be held in other United States regions. HubSpot, our customer-relationship-management subprocessor, processes personal information in Canada. As we add subprocessors or hosting arrangements over time, personal information handled through the Service may be transferred to, and processed and stored in, the United States, Canada and other jurisdictions where Scallor or its subprocessors operate, and is subject to the laws of the jurisdiction where it is held, including lawful access by that jurisdiction's courts, law-enforcement and government authorities.

Scallor remains accountable for personal information transferred across borders and requires each subprocessor, by contract, to protect it at a level comparable to the protection it would receive in Canada. We keep the subprocessor list current as our hosting footprint changes, under the change-notice and objection process in Section 5. Dedicated regions for Canada, the United Kingdom and the European Union, and Asia-Pacific are on our roadmap, prioritised by customer demand. The storage location is disclosed in every customer agreement.

Scallor has not conducted a privacy impact assessment for cross-border transfer. Where Data Protection Laws require one, we will conduct it and will assist a customer conducting its own, as the Data Processing Addendum provides.

Scallor maintains administrative, technical and physical safeguards designed to protect personal information against loss, theft and unauthorised access, use or disclosure. Current controls:

• Tenant isolation: row-level security in the application database, designed so that one customer's data is not accessible to another.
• Encryption: AES-256 at rest and TLS 1.3 in transit.
• Back-ups: encrypted, and purged on rotation as Section 7 describes.
• Audit logging: append-only logging of access and key events.
• Log hygiene: application logging is configured to exclude personal information. We do not warrant that no personal information will ever appear in a log, and we remediate on discovery.
• Access control: access to personal information is limited to personnel who need it, governed by authentication and least-privilege controls, and removed on departure. All personnel with access are bound by written confidentiality obligations.
• Product security: dependency and source-code vulnerability scanning, and source-code access control.
• Physical: Scallor operates no data centre. Physical security is provided by our infrastructure subprocessors.

Scallor holds no third-party security certification. No safeguard is perfect, and no method of transmission or storage is completely secure. We review and improve our controls as the product and the threat environment change.

If a privacy breach occurs. Scallor maintains controls to detect and investigate security incidents. A formal documented incident response procedure is in development and is not yet in place.

If a breach of security safeguards creates a real risk of significant harm to an individual, Scallor will notify the Office of the Privacy Commissioner of Canada and affected individuals as soon as feasible, keep the records the law requires, and notify affected customers so they can meet their own obligations. As a commitment to our customers, Scallor will report a confirmed breach of security safeguards affecting their data without undue delay and in any event within 48 hours of confirming it, as our customer agreements require. For personal information inside a customer's account, notification to a regulator or to individuals is the customer's responsibility, as Section 8 describes. Report a suspected incident to [email protected].

Scallor is a business tool. This site and product are intended for business audiences. We do not knowingly collect personal information from anyone under the age of majority in their province or territory. If you believe a child's personal information has reached Scallor, contact the Privacy Officer and we will delete it.

We may update this notice as the product and our data practices change. We will post the updated notice with a new "Last updated" date. Where a change materially affects how we handle your personal information, we will give notice before it takes effect and, where the law requires, seek your consent. If we materially change how we handle personal information collected through this website, we will re-prompt for consent through the cookie banner. Continuing to use the Service after an update takes effect means you accept the updated notice.

Direct any question, request or complaint about your personal information to the Privacy Officer: Sulakshana Arora, [email protected], 2 Robert Speck Pkwy, Suite 750, Mississauga, ON L4Z 1H8, Canada. We will acknowledge your request and respond within the time the law requires.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada. Individuals in Quebec may contact the Commission d'accès à l'information. Individuals in Alberta or British Columbia may contact their provincial Information and Privacy Commissioner.

See also our Cookie Policy, Terms of Use, and Trust & Compliance Centre.