Privacy Policy
Effective Date: April 30, 2026 | Version 1.0
This Privacy Policy explains how Cuemby LLC, doing business as ScaleUp Summit Network (“ScaleUp,” “we,” “our”), collects, uses, shares, and protects personal and business information submitted through the ScaleUp Summit Platform and related programs. By applying to or participating in ScaleUp Summit, you acknowledge that you have read and understood this Privacy Policy.
The data controller responsible for your information is:
Cuemby LLC, doing business as ScaleUp Summit Network
Registered in the State of Florida, United States
Privacy contact: privacy@scaleupsummit.network
ScaleUp Summit Network is a commercial brand operated by Cuemby LLC and does not constitute a separate legal entity. All data processing obligations are owned and administered by Cuemby LLC.
For purposes of this Privacy Policy, the following terms have the meanings set forth below:
· “Platform” means the ScaleUp Summit online application, assessment tools, participant portal, and any associated digital interfaces operated by Cuemby LLC in connection with the ScaleUp Summit program.
· “Participants” means individuals and organizations that apply to or take part in ScaleUp Summit programs, including applicants, attendees, and assessed companies.
· “Program” means the ScaleUp Summit structured evaluation and readiness program, including all associated events, assessments, workshops, and post-event activities.
· “Program Outputs” means deliverables generated by ScaleUp as a result of the technical assessment process, including the Tech Readiness Score, gap analysis, and optimization roadmaps.
· “Sponsors” and “Partners” means third-party organizations that participate in the ScaleUp Summit ecosystem through sponsorships, technical sessions, clinics, or post-event engagements.
This Privacy Policy applies to all personal and business information collected in connection with:
· Applications to participate in ScaleUp Summit Programs
· Registration for events, workshops, and related sessions
· Participation in technical assessments and the Tech Readiness evaluation process
· Interactions with Sponsors, Partners, or post-event programs facilitated by ScaleUp
· Use of the Platform and any associated tools or communications
This Privacy Policy applies to Participants located in the United States and in the various LATAM markets currently served by ScaleUp Summit. Jurisdiction-specific notices are provided in Section 12.
We collect only the information necessary to deliver Program value, conduct technical evaluations, and maintain quality standards. Information is collected across the following categories:
· Full name
· Email address and contact details
· Job title and organizational role
· Company affiliation
· Company name, industry, and operational stage
· Product description and go-to-market information
· Team composition and organizational structure
· Revenue stage, traction metrics, and growth indicators
As part of the ScaleUp methodology, we collect the following categories of technical information:
· Software architecture and infrastructure configuration
· Development, deployment, and operational practices
· Product maturity indicators and readiness benchmarks
· Responses and materials submitted during assessments or workshops
Technical assessment data is treated with heightened confidentiality. It is used exclusively for generating Program Outputs and anonymized benchmarking. It is not shared with Sponsors or Partners in identifiable form without your explicit consent.
When you access and use the Platform, we may automatically collect the following data:
· Log data, IP addresses, and device identifiers
· Session activity and navigation patterns within the Platform
· Browser type, operating system, and referring URLs
· Communications submitted through the Platform or via ScaleUp contact channels
The Platform may use cookies or similar tracking technologies to maintain session state, analyze usage patterns, and improve Platform performance. Participants may disable cookies through their browser settings; however, doing so may limit certain Platform functionality. A separate Cookie Notice will be published at www.scaleupsummit.network/cookies.
ScaleUp Summit does not currently collect payment or financial information from Participants. If fee-based services are introduced in the future, this Privacy Policy will be updated with advance notice prior to any collection of payment data. Payment processing will be handled through a compliant third-party processor, and Cuemby LLC will not store raw payment card data.
We process personal and business information on the following legal bases:
(a) Program Participation. Processing is necessary to deliver ScaleUp Summit programming, including eligibility evaluation, technical assessments, and the generation of Program Outputs such as the Tech Readiness Score, gap analysis, and optimization roadmaps.
(b) Legitimate Interests. ScaleUp has a legitimate interest in improving Program quality, generating anonymized ecosystem insights, maintaining the integrity of its assessment processes, and marketing Cuemby LLC products and services to Participants based on their assessment results and identified technical gaps. These interests are proportionate, directly related to the Program context in which data was collected, and do not override Participants' rights. Participants may opt out of marketing communications at any time as described in Section 6.
(c) Consent. Where processing extends beyond Program delivery and legitimate interests — including sharing identifiable Participant information with Sponsors or Partners for commercial purposes, facilitating post-event introductions to named third parties, or featuring Participants in promotional materials — ScaleUp will obtain explicit, affirmative consent prior to that processing.
Consent for sponsor data sharing is collected at the point of registration through a dedicated, standalone consent checkbox, separate from acceptance of the Terms of Use. The checkbox will clearly identify:
The categories of Sponsors that may receive Participant data
The type of data that will be shared (company profile, contact details, and Program Outputs)
The commercial purpose of the transfer
The Participant's right to withdraw consent at any time
Consent is specific, recorded with a timestamp and Participant identifier, and revocable. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.
(d) Automated Processing Disclosure. The Tech Readiness Score and associated Program Outputs are generated through ScaleUp’s proprietary automated assessment methodology, which evaluates submitted data against defined benchmarks across multiple technical and operational dimensions. This automated process may produce outcomes that influence Program selection decisions, Sponsor introductions, and post-event opportunities. Participants have the right to request a human review of their Tech Readiness Score and to contest any output they believe is inaccurate or incomplete by contacting ScaleUp at the address in Section 13.
Participants located in jurisdictions with applicable data protection requirements will receive a jurisdiction-specific consent notice at the point of application or registration, as required by local law. See Section 12 for jurisdiction-specific details.
Consent may be withdrawn at any time by contacting us as described in Section 13. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.
Information collected is used exclusively for the following purposes:
· Evaluating eligibility and curating Participant selection for ScaleUp Summit Programs
· Delivering programming, workshops, assessments, and related sessions
· Generating Program Outputs, including the Tech Readiness Score, gap analysis, and optimization roadmaps
· Facilitating ecosystem connections, introductions, and networking within the Program context
· Providing post-event follow-up opportunities, including services, sprints, and partnerships, subject to Participant consent
· Marketing Cuemby LLC products and services to Participants based on their assessment results and identified technical gaps, under the legitimate interests basis described in Section 4(b). Participants may opt out of these communications at any time by contacting ScaleUp at the address in Section 13 or by using the unsubscribe link in any marketing communication.
· Sharing identifiable Participant data — including company profile, contact details, and Program Outputs — with Sponsors where the Participant has provided explicit consent at registration, as described in Section 4(c).
· Improving Program quality and generating anonymized ecosystem benchmarks
· Complying with applicable legal obligations
ScaleUp does not use Participant information for advertising, profiling unrelated to the Program, or sale to any third party.
ScaleUp operates within a multi-partner ecosystem. The following rules govern all data sharing:
Anonymized and aggregated data may be shared with Sponsors, Partners, and ecosystem stakeholders without individual consent, provided no Participant can be identified from the data.
Identifiable Participant data — including contact details, company profiles, and Program Outputs — will only be shared with Sponsors or Partners where explicit, affirmative consent has been obtained from the Participant prior to sharing, by affirmatively consenting at the point of registration or through a subsequent consent flow. Consent is specific to the receiving party and the purpose of sharing, recorded with a timestamp and Participant identifier, and revocable at any time.
ScaleUp may share information without individual consent only in the following limited circumstances:
· With Program delivery partners (technical, legal, or operational experts) directly involved in delivering ScaleUp Summit, under confidentiality obligations
· As aggregated, anonymized insights that cannot be used to identify any individual or company
· As required by applicable law, regulation, or enforceable governmental request
Sponsors and Partners who receive Participant data under a consent agreement are contractually prohibited from using that data for purposes outside the agreed scope. ScaleUp is not liable for unauthorized use by Sponsors or Partners following disclosure made in accordance with Participant consent. ScaleUp’s liability arising from this Privacy Policy is subject to the limitations set forth in the ScaleUp Summit Terms of Use. Participants who believe their data has been misused should contact ScaleUp immediately at the address in Section 13.
ScaleUp does not sell, rent, or distribute Participant data to any third party for commercial purposes.
Participants retain ownership of the underlying data and materials they submit to ScaleUp. By submitting information through the Platform, Participants grant Cuemby LLC a non-exclusive, royalty-free, worldwide license to use submitted data for the following purposes:
· Delivering Program Outputs to the Participant
· Generating anonymized benchmarks and ecosystem analytics
· Improving the ScaleUp assessment methodology and Platform
This license does not include the right to identify the Participant in external publications or promotional materials without separate consent.
The ScaleUp assessment methodology, scoring framework, Tech Readiness Score, gap analysis outputs, optimization roadmaps, and all related tools, models, and reports are the exclusive intellectual property of Cuemby LLC. Participation in ScaleUp Summit does not transfer, license, or imply any rights to these tools or frameworks beyond the Participant’s own deliverables. Participants may not reproduce, distribute, reverse-engineer, or publicly disclose the ScaleUp methodology or scoring framework without prior written authorization from Cuemby LLC.
Participant data may be processed and stored in the United States. By affirmatively consenting at the point of registration, Participants located in Colombia, Ecuador, Mexico, Peru, Costa Rica, Guatemala, or other jurisdictions authorize the transfer and processing of their data in the United States.By participating in ScaleUp Summit Network, you agree to:
Where such transfers are subject to local regulatory requirements, ScaleUp implements appropriate safeguards, including data processing agreements with applicable Partners and contractual protections consistent with local law. The applicable transfer mechanism for each jurisdiction is:
· Colombia: Participant authorization under Decreto 1377/2013, Article 26
· Ecuador: Consent-based transfer under LOPDP Article 41
· Mexico: Consent-based transfer under LFPDPPP Article 36
· Peru: Participant authorization under Ley 29733, Article 15
· Costa Rica and Guatemala: Consent-based transfer consistent with applicable local standards
Participants may request information about applicable transfer safeguards by contacting ScaleUp at the address in Section 13.
We retain Participant data only for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following guidelines:
· Program Outputs (Tech Readiness Score, gap analysis, roadmaps) are retained for 24 months following the date on which Program Outputs are made available to the Participant through the Platform or via email, after which they are deleted or fully anonymized unless the Participant requests earlier deletion.
· Application and registration data is retained for 12 months following the conclusion of the Program cycle to which it relates.
· Anonymized and aggregated analytics data may be retained indefinitely, as no individual or company can be identified from such data.
· Data processed on the basis of consent is deleted within 30 calendar days of a valid withdrawal request, except where another lawful basis applies or where retention is required by law.
Retention periods may be extended where required by applicable law or where data is subject to a pending legal dispute.
ScaleUp implements reasonable and appropriate administrative, technical, and organizational safeguards to protect Participant data against unauthorized access, misuse, disclosure, loss, or alteration.
Access to Participant data is restricted to:
· Authorized ScaleUp team members with a need to access data for Program delivery
· Program delivery partners operating under confidentiality obligations
· Evaluation committees where applicable and with appropriate controls
ScaleUp cannot guarantee absolute security of data transmitted over the internet. Participants are responsible for maintaining the security of their own access credentials.
Subject to applicable law, Participants may exercise the following rights with respect to their personal and business information:
· Access — Request a copy of the personal data ScaleUp holds about you
· Correction — Request correction of inaccurate or incomplete information
· Deletion — Request deletion of your data, subject to retention obligations under Section 9
· Withdrawal of Consent — Withdraw consent for processing under Section 4(c) at any time
· Restriction — Request restriction of processing in certain circumstances
· Portability — Request your data in a structured, commonly used format where technically feasible
· Objection — Object to processing based on legitimate interests
· Human Review — Request human review of any automated assessment output, as described in Section 4(d)
To exercise any of these rights, submit a written request to privacy@scaleupsummit.network. ScaleUp will acknowledge receipt within 5 calendar days and will provide a substantive response within the timeframe required by applicable local law, and no later than 30 calendar days from receipt of a valid request. We may require identity verification before processing requests to protect Participant data from unauthorized disclosure.
Participants who believe their rights have not been adequately addressed may file a complaint with the applicable data protection authority in their jurisdiction.
Processing of personal data relating to Colombian residents is governed by Ley 1581 de 2012 and Decreto 1377 de 2013. Cuemby LLC acts as the responsible party (responsable del tratamiento). A formal Autorización for data processing will be presented to Colombian Participants at the point of registration. ScaleUp will respond to data access requests from Colombian residents within 10 business days, extendable to 15 business days where required. Colombian Participants may file complaints with the Superintendencia de Industria y Comercio (SIC).
Processing of personal data relating to Mexican residents is governed by the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP). A separate Aviso de Privacidad compliant with INAI guidelines is available upon request at privacy@scaleupsummit.network and will be provided to Mexican Participants at the point of registration.
Processing of personal data relating to Peruvian residents is governed by Ley Nº 29733 and its regulations. ScaleUp will respond to data access requests from Peruvian residents within 20 calendar days. Participants may exercise their rights before the Autoridad Nacional de Protección de Datos Personales (ANPDP).
Processing of personal data relating to Ecuadorian residents is governed by the Ley Orgánica de Protección de Datos Personales (LOPDP, 2021). ScaleUp processes Ecuadorian Participant data on the basis of consent and Program performance, consistent with the principles of the LOPDP.
Processing of personal data relating to Costa Rican residents is governed by Ley Nº 8968. Participants may exercise their rights before the Agencia de Protección de Datos de los Habitantes (PRODHAB).
Guatemala does not currently have a comprehensive data protection statute. ScaleUp applies the same consent and data minimization standards to Guatemalan Participants as to all other markets, consistent with internationally recognized privacy principles.
For Participants located in California, ScaleUp acknowledges rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know, delete, correct, and opt out of the sale or sharing of personal information. ScaleUp does not sell personal information. California residents may exercise their rights by contacting ScaleUp at the address in Section 13.
For questions about this Privacy Policy, to exercise your rights, or to submit a data-related complaint:
Cuemby LLC — Privacy Team
Email: privacy@scaleupsummit.network
Website: www.scaleupsummit.network
ScaleUp will acknowledge receipt of all requests within 5 calendar days and provide a substantive response within the timeframe required by applicable local law, and no later than 30 calendar days from receipt of a valid request.
ScaleUp reserves the right to update this Privacy Policy to reflect changes in data practices, applicable law, or Program scope. When material changes are made, ScaleUp will notify Participants via email or a prominent notice on the Platform at least 14 days prior to the change taking effect.
Continued participation in ScaleUp Summit following notice of a material change constitutes acceptance of the updated Privacy Policy. If you do not agree to the updated terms, you may withdraw from the Program and request deletion of your data under Section 11.
The version number and effective date at the top of this document will be updated with each revision.
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