Privacy Policy

Last Updated: July 2026

1. Who We Are

This Privacy Policy explains how ScaleGenius (Digital Culture L.L.C-Fz) ("we," "us," "our"), collects, uses, shares, and protects your personal data when you:

Visit our website at scalegenius.io or any associated landing pages and sales funnels (the "Website");

- Purchase or access our digital products, including the Nobody's Talkin' About You™ book bundle and our online courses;

- Create an account on our course platform;

- Book a strategy call, contact our support team, or otherwise communicate with us;

R- eceive marketing communications from us.

If you have any questions about this policy or our data practices, contact us at [email protected]

2. Personal Data We Collect

2.1 Data You Provide Directly

Identity & contact data: name, email address, phone number, business name, and (where relevant) job title or business type.

Purchase & transaction data: products purchased, order value, currency, purchase date, billing details, and country. We do not collect or store your full payment card details — payments are handled by our payment processors (see Section 6).

Account data: login credentials and course progress on our course platform.

Communications data: the content of emails, support requests, survey responses, strategy call bookings, and any feedback, reviews, or testimonials you provide.

Marketing preferences: your subscription status and consent records.

2.2 Data Collected Automatically

When you visit the Website, we and our service providers automatically collect:

Device & technical data: IP address, browser type and version, operating system, device type, and screen size.

Usage data: pages viewed, time on page, scroll depth, video plays, links and buttons clicked, referral source, and the funnel path you take through our pages.

Cookie & tracking data: identifiers set by cookies, pixels, and similar technologies, including the Meta Pixel and analytics tools (see Section 7).

2.3 Data From Third Parties

We may receive data about you from: payment processors (payment confirmation, fraud signals); advertising platforms such as Meta (campaign interaction data, aggregated audience data); our course platform and CRM (engagement data); and scheduling tools (call booking details).

2.4 Special Category Data & Children

We do not knowingly collect special category data (such as health data) or any data from children under 18. Our products are intended for adults purchasing for business education. If you believe a child has provided us with personal data, contact us and we will delete it.

3. How and Why We Use Your Personal Data

Under UK GDPR, we must have a lawful basis for each use of your data. The table below sets out what we do and why.

Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms and concluded they are not overridden. You may object at any time (see Section 10).

4. Marketing Communications

If you purchase from us, opt in via a form, or download our materials, we may send you marketing emails about our products, training, and offers.

You can unsubscribe at any time using the link in any marketing email or by emailing [email protected]

Unsubscribing from marketing does not stop essential service emails (e.g., receipts, access information, legal notices).

We comply with the Privacy and Electronic Communications Regulations (PECR) in the UK and applicable anti-spam laws elsewhere (including CAN-SPAM in the US).

If you provide a phone number and consent, we may contact you by SMS or phone regarding bookings or offers; you may opt out at any time by replying STOP or contacting us.

5. Cookies, Pixels & Tracking Technologies

We use cookies and similar technologies on the Website, including:

Essential cookies — required for the Website, checkout, and course platform to function. These cannot be switched off.

Analytics cookies — help us understand how visitors use our pages and funnels so we can improve them.

Advertising cookies and pixels — including the Meta Pixel and similar tools, which track actions you take on our Website (such as page views, button clicks, and purchases) and share that data with the advertising platform to measure our ads, build audiences, and show you relevant ads on other platforms.

Where required by law, non-essential cookies are set only with your consent via our cookie banner, and you can withdraw or change your consent at any time via [COOKIE SETTINGS LINK]. You can also control cookies through your browser settings, though blocking some cookies may affect Website functionality. For more detail, see our Cookie Policy at [LINK] (if maintained separately).

6. Who We Share Your Data With

We do not sell your personal data for money. We share personal data with the following categories of recipients, only as needed:

Course & funnel platforms: Kajabi (course hosting and delivery) and GoHighLevel/LeadConnector (landing pages, CRM, email/SMS delivery, booking).

Payment processors: e.g., Stripe and/or PayPal (or as listed at checkout), who process your payment data as independent controllers under their own privacy policies.

Email and communications providers used to deliver service and marketing messages.

Advertising and analytics partners: Meta Platforms (Meta Pixel, Custom Audiences using hashed identifiers) and analytics providers.

Cloud hosting, storage, and IT service providers.

Professional advisers: accountants, lawyers, and insurers where necessary.

Authorities and other parties where required by law, to enforce our terms, to prevent fraud, or to protect rights, property, or safety.

A buyer or successor in the event of a merger, acquisition, or sale of all or part of our business — your data would remain subject to protections consistent with this policy.

Service providers acting as our processors may only use your data on our instructions and under contracts containing appropriate data protection obligations.

7. International Transfers

We are based in the United Kingdom, and several of our service providers (including Kajabi, GoHighLevel, Meta, and payment processors) are based in or store data in the United States and other countries outside the UK.

Where your personal data is transferred outside the UK, we ensure appropriate safeguards are in place, such as: UK adequacy regulations (including the UK–US Data Bridge where the recipient is certified); the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses; or other lawful transfer mechanisms. You may contact us for more information about the safeguards applied to specific transfers.

8. How Long We Keep Your Data

We keep personal data only as long as necessary for the purposes described in this policy:

Customer and transaction records: generally 6 years after the transaction, to meet UK tax, accounting, and legal claim limitation requirements.

Course accounts: for as long as your access remains active, plus a reasonable period thereafter.

Marketing data: until you unsubscribe or your data becomes inactive under our list-hygiene practices, after which it is suppressed or deleted.

Support communications: typically up to 3 years after resolution.

Cookie data: for the lifespan stated in our cookie tool/banner.

When data is no longer needed, we delete it or irreversibly anonymise it.

9. How We Protect Your Data

We implement appropriate technical and organisational measures to protect your personal data, including encrypted connections (HTTPS/TLS), access controls, reputable hosted platforms, and limiting access to personnel who need it. No method of transmission or storage is completely secure, but we work to protect your data and will notify you and the relevant authority of any breach where legally required.

10. Your Rights (UK & EU)

If you are in the UK or EU, you have the following rights regarding your personal data:

Access — request a copy of the personal data we hold about you;

Rectification — have inaccurate or incomplete data corrected;

Erasure — request deletion of your data in certain circumstances;

Restriction — request that we limit how we use your data in certain circumstances;

Portability — receive certain data in a structured, machine-readable format;

Objection — object to processing based on legitimate interests, and object at any time to direct marketing (which we will always honour);

Withdraw consent — at any time, where processing is based on consent, without affecting prior processing;

Automated decisions — we do not make legally significant decisions about you based solely on automated processing.

To exercise any right, email [PRIVACY EMAIL]. We will respond within one month (extendable for complex requests). We may need to verify your identity first. These rights are subject to legal exemptions.

Complaints: you have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk or +44 303 123 1113 (or your local EU supervisory authority). We would appreciate the chance to address your concerns first.

11. Additional Information for US Residents

If you are a resident of California or another US state with comprehensive privacy legislation (e.g., Virginia, Colorado, Connecticut, Texas), you may have rights including: the right to know/access the personal information we collect; the right to delete; the right to correct; and the right to opt out of "sale" or "sharing" of personal information and targeted advertising.

Categories collected: identifiers, commercial information, internet activity, and inferences, as described in Section 2.

"Sharing"/targeted advertising: our use of advertising cookies and pixels (such as the Meta Pixel) may constitute "sharing" for cross-context behavioural advertising under California law. You can opt out via our cookie banner or by emailing [email protected] with the subject "Do Not Sell or Share My Personal Information." We also honour Global Privacy Control (GPC) signals where required.

No discrimination: we will not discriminate against you for exercising your privacy rights.

Authorised agents may submit requests on your behalf with proof of authorisation.

12. Third-Party Websites & Platforms

The Website and our products contain links to, and training about, third-party websites and tools (including Kajabi, GoHighLevel, Meta, and AI software providers). This policy does not cover those third parties. We encourage you to review the privacy policies of any third-party service you use.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top shows the current version. Material changes will be posted on the Website and, where appropriate, notified by email. Please review this page periodically.

14. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or your personal data:

Email: [email protected]

Website: scalegenius.io

This Privacy Policy was last reviewed on July 2026