Effective Date: July 23, 2026

This Privacy Policy explains how 6IX Media Group Limited, operating under the Scale Certified brand (“Scale Certified,” “we,” “us,” or “our”), collects, uses, stores, shares and protects personal information in connection with the Agency Lab, including its websites, membership, Content Portal, GoHighLevel access, community, coaching, artificial intelligence tools, customer support and related services.

We take the privacy of our Members, prospective Members and other individuals whose information we process seriously.

This Privacy Policy should be read together with the Agency Lab Terms of Use and, where applicable, the Scale Certified GoHighLevel Terms of Use.

1. WHO WE ARE

The primary data controller responsible for personal information collected in connection with Agency Lab is:

6IX Media Group Limited

Company Number: SC650838

Email: [email protected]

6IX Media Group Limited is a company registered in Scotland.

Scale Certified Inc., a Canadian corporation, acts as a payment-processing and administrative representative for 6IX Media Group Limited and may process certain personal information on our behalf in connection with billing, payments, account administration and the operation of Agency Lab.

Depending on the particular processing activity, third-party service providers may also process personal information on our behalf or as independent controllers under their own privacy policies.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information we collect or process in connection with:

* Agency Lab sales and enrollment pages;

* the $1 Agency Lab trial;

* Agency Lab subscriptions;

* the Agency Lab Content Portal;

* Agency Lab GoHighLevel accounts and sub-accounts;

* Agency Lab coaching calls and workshops;

* the Agency Lab community;

* customer support;

* Agency Lab artificial intelligence tools;

* email communications;

* marketing and advertising;

* testimonials, reviews and case studies;

* website analytics;

* cookies, pixels and similar technologies;

* account security and authentication;

* billing and payment administration; and

* other activities directly connected to Agency Lab.

This Policy does not replace the privacy policy that an Agency Lab Member may be required to provide to their own customers, leads, prospects, employees or clients.

3. AGENCY LAB IS A BUSINESS SERVICE

Agency Lab is intended for business-to-business use.

We nevertheless recognise that information relating to an individual business owner, employee, contractor, sole trader, representative or other identifiable person may constitute personal data under applicable privacy and data protection laws.

We therefore process such information in accordance with this Privacy Policy and applicable law.

Agency Lab is not intended for children or individuals under eighteen (18) years of age.

4. PERSONAL INFORMATION WE COLLECT

The information we collect depends on how you interact with Agency Lab.

We may collect the following categories of personal information.

4.1 Identity Information

This may include:

* first name;

* last name;

* username;

* account identifier;

* business owner or representative information; and

* other information used to identify your account.

4.2 Contact Information

This may include:

* email address;

* telephone number;

* mailing or business address;

* country;

* region;

* postcode or ZIP code; and

* other contact details you provide.

Where a GoHighLevel account or sub-account is created, additional address or business location information may also be requested.

4.3 Business Information

This may include:

* business name;

* trading name;

* industry or niche;

* website;

* business address;

* business telephone number;

* business email;

* services offered;

* business goals;

* information about your agency or clients;

* account configuration information; and

* other information you voluntarily provide about your business.

4.4 Membership and Account Information

This may include:

* Agency Lab enrollment date;

* membership level;

* trial information;

* subscription status;

* billing frequency;

* grandfathered pricing status;

* pause status;

* cancellation status;

* login information;

* Content Portal activity;

* account permissions;

* courses accessed;

* resources used;

* GoHighLevel account information; and

* other information relating to your Agency Lab membership.

4.5 Transaction and Payment Information

We may collect information relating to:

* payments;

* subscription charges;

* trial payments;

* renewal payments;

* transaction dates;

* payment status;

* failed payments;

* refunds, where applicable;

* chargebacks;

* invoices;

* GoHighLevel usage charges;

* taxes;

* currency;

* payment method type; and

* billing history.

Our primary payment processor is Stripe.

In limited circumstances, payments may also be processed using providers such as PayPal or Wise.

We do not ordinarily manually collect or store your complete credit or debit card number.

Payment credentials are generally collected and stored by the applicable payment processor or, for GoHighLevel sub-account billing, through systems operated by Stripe and/or GoHighLevel.

Those providers may process your information under their own privacy and security practices.

4.6 Technical and Device Information

When you access our websites, portals or online services, we or our technology providers may automatically collect information such as:

* IP address;

* browser type;

* browser version;

* device type;

* operating system;

* device identifiers;

* language;

* approximate geographic location derived from IP address;

* referring URL;

* pages visited;

* time and date of visits;

* actions taken on our website;

* session information;

* login activity;

* cookie identifiers;

* advertising identifiers; and

* similar technical information.

4.7 Support and Communications Information

If you communicate with us, we may retain:

* emails;

* support requests;

* questions;

* complaints;

* account requests;

* troubleshooting information;

* attachments;

* screenshots;

* chat messages;

* WhatsApp communications;

* GoHighLevel conversations; and

* other correspondence.

These communications are generally retained within the platform through which they occurred and may also be transferred to another internal system where reasonably necessary to provide support or maintain an appropriate business record.

4.8 Community Information

If you participate in the Agency Lab community, we may process information including:

* your name;

* telephone number where associated with WhatsApp;

* WhatsApp profile information;

* profile image;

* messages;

* questions;

* comments;

* reactions;

* shared files;

* voice notes;

* business information;

* community participation; and

* information you voluntarily share with other Members.

4.9 Coaching, Workshop and Recording Information

Agency Lab coaching calls, workshops and similar sessions may be recorded.

Depending on how you participate, recordings may contain:

* your name;

* image;

* voice;

* questions;

* comments;

* chat messages;

* screen shares;

* business information;

* examples you discuss; and

* other contributions.

Calls are currently commonly hosted using Google Meet.

Google's Gemini functionality may also be used to:

* take meeting notes;

* generate transcripts;

* create meeting summaries; and

* assist with organising or identifying information discussed during calls.

4.10 AI Interaction Information

Agency Lab includes an internal AI Agent currently powered through the GoHighLevel platform.

When you use this AI Agent, we may process:

* prompts;

* questions;

* messages;

* AI responses;

* conversation history;

* feedback;

* usage information;

* business information you include in your prompt;

* AI conversation summaries; and

* other information contained in the interaction.

Conversations are currently stored within GoHighLevel.

Authorised Scale Certified personnel may review AI conversations through the relevant GoHighLevel account.

We may also receive emailed summaries of AI conversations.

AI conversations and summaries may be analysed to:

* provide the AI service;

* improve Agency Lab support;

* identify recurring Member questions;

* identify gaps in the Agency Lab Knowledge Base;

* improve Knowledge Base resources;

* improve the internal Agency Lab AI experience;

* identify areas where additional training may be useful; and

* troubleshoot AI responses.

4.11 Marketing and Advertising Information

We may collect information relating to your interaction with our marketing, including:

* emails opened;

* links clicked;

* advertisements viewed;

* advertisements clicked;

* forms submitted;

* pages visited;

* purchases;

* campaign attribution;

* source or referral information;

* marketing preferences;

* audience membership; and

* advertising identifiers.

4.12 Testimonials and Results

Where you voluntarily provide a testimonial, review, success story or other feedback, we may process information including:

* your name;

* business name;

* business results;

* photograph;

* profile image;

* written testimonial;

* audio;

* video;

* voice;

* screenshots;

* revenue or sales information you voluntarily disclose; and

* other information associated with the testimonial.

5. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

5.1 Directly From You

For example when you:

* purchase Agency Lab;

* begin a trial;

* complete a form;

* create an account;

* request a GoHighLevel sub-account;

* provide billing details;

* contact support;

* participate in a coaching call;

* join the community;

* use the Agency Lab AI Agent;

* submit a testimonial;

* respond to a survey;

* register for an event or workshop;

* send us an email; or

* otherwise communicate with us.

5.2 Automatically

Information may be collected automatically when you interact with our websites, emails, advertisements, Content Portal or other digital services through cookies, pixels, analytics tools, log files and similar technology.

5.3 From Service Providers

We may receive information from providers involved in operating Agency Lab, such as:

* payment processors;

* GoHighLevel;

* website and analytics providers;

* email platforms;

* authentication providers;

* advertising platforms;

* community platforms; and

* other technology providers.

5.4 From Public Sources

Where you voluntarily publish information about Agency Lab publicly, such as through a review, testimonial or social media post, we may become aware of and process that information where reasonably appropriate and lawful.

6. HOW AND WHY WE USE PERSONAL INFORMATION

We may use personal information for the following purposes.

6.1 To Provide Agency Lab

We process information to:

* create your membership;

* activate your trial;

* provide Content Portal access;

* create GoHighLevel accounts;

* create requested sub-accounts;

* provide templates and resources;

* provide community access;

* provide coaching;

* provide AI tools;

* authenticate your account;

* administer pauses and cancellations; and

* otherwise deliver the Services.

6.2 To Process Payments

We process relevant information to:

* collect membership payments;

* collect trial payments;

* process recurring subscriptions;

* rebill GoHighLevel usage;

* process taxes;

* identify failed transactions;

* administer payment disputes;

* maintain financial records; and

* prevent fraudulent transactions.

6.3 Customer Support

We process information to:

* respond to questions;

* troubleshoot problems;

* access GoHighLevel accounts where necessary;

* investigate account issues;

* provide technical assistance;

* process account requests;

* investigate billing issues;

* administer cancellations or pauses; and

* otherwise support Members.

6.4 Service Administration and Improvement

We may process information to:

* understand how Agency Lab is used;

* improve training;

* improve templates;

* improve support;

* improve onboarding;

* identify recurring problems;

* improve our Knowledge Base;

* develop new Agency Lab features;

* improve our AI tools;

* evaluate service performance; and

* understand Member engagement.

6.5 Security and Fraud Prevention

We may process information to:

* authenticate users;

* support two-factor authentication;

* protect accounts;

* prevent unauthorised access;

* investigate suspicious behaviour;

* prevent payment fraud;

* enforce our Terms;

* protect our systems; and

* protect Members and third parties.

Telephone numbers may, for example, be used for two-factor authentication and account security.

6.6 Communications

We may use contact information to send:

* membership information;

* transaction confirmations;

* billing notices;

* account notifications;

* support responses;

* service announcements;

* workshop information;

* coaching information;

* community information;

* important legal or policy notices; and

* other operational communications.

6.7 Marketing

Where permitted by applicable law, we may use personal information to market:

* Agency Lab;

* other Scale Certified products;

* workshops;

* training;

* offers;

* promotions;

* events;

* upgrades;

* new products; and

* other relevant business services.

Marketing communications may be personalised based on your relationship with us, previous interactions, interests or activities where permitted by law.

You may unsubscribe from marketing emails at any time using the unsubscribe link contained at the bottom of our marketing emails.

Unsubscribing from marketing does not prevent us from sending necessary transactional, account, security or service communications.

6.8 Advertising and Audience Measurement

Subject to applicable law and required consent, we may use information to:

* measure advertising effectiveness;

* attribute sales or leads to campaigns;

* create advertising audiences;

* retarget website visitors;

* suppress existing customers from certain campaigns;

* create similar or lookalike audiences;

* measure conversions;

* optimise advertising campaigns; and

* understand the effectiveness of our marketing.

6.9 Legal and Regulatory Purposes

We may process personal information where necessary to:

* comply with legal obligations;

* maintain accounting records;

* respond to lawful requests;

* establish or defend legal claims;

* enforce contractual rights;

* respond to regulators;

* prevent unlawful activity; and

* comply with tax, corporate or financial requirements.

7. OUR LAWFUL BASES FOR PROCESSING

Where UK GDPR, EU GDPR or similar legislation requires a lawful basis for processing, we may rely on one or more of the following bases.

7.1 Performance of a Contract

We process information where necessary to enter into or perform our agreement with you.

Examples include:

* creating your Agency Lab account;

* providing Content Portal access;

* providing GoHighLevel access;

* delivering Member resources;

* administering your subscription;

* processing service requests; and

* providing customer support.

7.2 Legitimate Interests

We may process personal information where it is necessary for our legitimate business interests and those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

* operating Agency Lab;

* providing and improving our services;

* understanding Member needs;

* providing effective customer support;

* securing our platforms;

* preventing fraud;

* enforcing agreements;

* developing products;

* identifying Knowledge Base gaps;

* improving our internal AI Agent;

* maintaining appropriate business records;

* promoting relevant business services where legally permitted;

* measuring business performance; and

* protecting our legal and commercial interests.

7.3 Consent

We rely on consent where it is required or appropriate.

Examples may include:

* certain marketing communications;

* non-essential cookies or tracking technologies;

* certain advertising activities;

* specific testimonial uses;

* certain uses of your image, voice or likeness; and

* other processing for which applicable law requires consent.

Where we rely on consent, you may withdraw that consent at any time.

Withdrawal does not make processing that occurred before withdrawal unlawful.

7.4 Legal Obligation

We may process information where necessary to comply with a legal obligation, including accounting, tax, corporate, regulatory and law-enforcement requirements.

7.5 Legal Claims

Where permitted by applicable law, we may process and retain information where necessary to establish, exercise or defend legal claims.

8. MEMBER CLIENT AND PROSPECT DATA

This section is particularly important for Agency Lab Members using GoHighLevel for their own businesses and clients.

8.1 Member-Controlled Data

Agency Lab Members may use GoHighLevel sub-accounts to collect, upload, store and process personal information relating to their own:

* leads;

* prospects;

* customers;

* clients;

* website visitors;

* employees;

* contractors; and

* other contacts.

For this information, the Agency Lab Member will ordinarily determine why and how the information is processed and will ordinarily act as the data controller or business responsible for that information.

In some circumstances, the Member may themselves be acting as a processor on behalf of one of their clients.

8.2 Our Role

Because Agency Lab GoHighLevel accounts are provisioned within our GoHighLevel environment, authorised Scale Certified personnel have administrative access to those accounts.

We may therefore be technically capable of viewing personal information contained within them.

Where we process this information solely to provide Agency Lab, administer the platform, provision accounts, provide support, troubleshoot technical issues, maintain security or carry out the Member's documented instructions, we generally act as a processor or service provider on behalf of the Member, or as a sub-processor where the Member is itself acting as a processor.

8.3 HighLevel

GoHighLevel/HighLevel provides the underlying platform and may process data stored within the platform in accordance with its applicable agreements, Data Processing Addendum, privacy policies and sub-processor arrangements.

8.4 We Do Not Market to Member Client Lists

We do not use the contacts, leads, customers or client lists stored by Agency Lab Members inside their GoHighLevel accounts to market Scale Certified products or services to those individuals.

Our own marketing activities use information obtained through our own lead-generation, customer and marketing activities.

8.5 Member Responsibilities

Agency Lab Members are responsible for:

* determining their own lawful basis for processing;

* providing their own privacy notices where required;

* obtaining legally required consent;

* honouring data subject rights;

* ensuring their client contracts appropriately address data processing;

* ensuring their use of GoHighLevel complies with applicable privacy law;

* ensuring they have authority to upload data;

* obtaining appropriate communications consent; and

* complying with applicable data protection, privacy and marketing laws.

This Privacy Policy is not a substitute for a Member's own privacy policy.

8.6 Data Processing Terms

Where we act as a processor of personal data on behalf of an Agency Lab Member, additional contractual data-processing terms may apply.

This Privacy Policy describes our privacy practices but is not intended by itself to replace any data-processing agreement required under applicable law.

9. ACCESS TO GOHIGHLEVEL ACCOUNTS

Authorised Scale Certified personnel may access Agency Lab GoHighLevel accounts when reasonably necessary for purposes including:

* account provisioning;

* technical support;

* troubleshooting;

* template installation;

* investigating reported issues;

* security;

* account administration;

* billing support;

* enforcing applicable Terms;

* preventing misuse; and

* complying with legal obligations.

Access does not mean we claim ownership of a Member's client information.

Personnel should only access information to the extent reasonably necessary for an authorised operational purpose.

10. INTERNAL AGENCY LAB AI AGENT

10.1 How It Works

Agency Lab currently provides an internal AI Agent through GoHighLevel.

Interactions with this AI Agent may be stored within the GoHighLevel platform.

Authorised personnel may review those interactions.

We may also receive AI-generated conversation summaries by email.

10.2 Why We Review AI Conversations

We may review and analyse AI interactions to:

* answer Member questions;

* troubleshoot incorrect responses;

* improve the AI experience;

* identify commonly requested information;

* identify missing Knowledge Base content;

* expand or improve Agency Lab resources;

* improve support; and

* understand how Members use the AI Agent.

10.3 Third-Party AI Processing

The underlying AI functionality is provided through GoHighLevel and may involve technology providers or sub-processors used by HighLevel.

Their processing of information is governed by their applicable agreements, privacy policies, data-processing terms and provider arrangements.

We do not intentionally provide Agency Lab AI conversations to third-party foundation-model providers for the independent purpose of training general-purpose AI models.

However, because the functionality is provided through third-party infrastructure, we cannot independently represent that no third-party technical provider processes information in connection with operating or improving its contracted services.

10.4 Do Not Submit Unnecessary Sensitive Information

You should not use the Agency Lab AI Agent to submit unnecessary sensitive or confidential information.

In particular, please do not submit:

* complete payment-card details;

* passwords;

* authentication codes;

* government identification numbers;

* highly confidential client information;

* special-category personal data;

* medical or health information;

* biometric information;

* criminal-offence information; or

* other sensitive information unless it is genuinely necessary and you have a lawful basis and authority to process it.

You remain responsible for information you choose to enter into AI tools.

11. LIVE COACHING CALLS, RECORDINGS, TRANSCRIPTS AND NOTES

Agency Lab coaching calls, workshops, group sessions and similar events may be recorded.

Google Meet is currently commonly used for these sessions.

Google Gemini or similar functionality may generate:

* transcripts;

* summaries;

* notes;

* action items; and

* other meeting-generated information.

Recordings may subsequently be uploaded to the Agency Lab Content Portal or another training library.

11.1 Visibility to Other Members

Because recordings may be used as Agency Lab replay or educational content, your:

* name;

* voice;

* image;

* questions;

* comments;

* chat messages; and

* contributions

may be visible or audible to other Agency Lab Members who access the recording.

Please consider this before sharing confidential, personal or client-specific information during a group session.

11.2 Retention of Recordings

Recordings, transcripts and related materials may be retained on an ongoing basis for as long as they remain part of the Agency Lab training, replay or educational library or are otherwise reasonably required for the purposes for which they were collected.

Some recordings may therefore be retained for an extended period.

Where a recording is no longer required for a legitimate purpose, we may delete, archive, edit or anonymise it where reasonably appropriate.

12. WHATSAPP AND COMMUNITY PARTICIPATION

The Agency Lab community is currently commonly hosted using WhatsApp.

When you join a WhatsApp group or community, certain information may become visible to other participants according to WhatsApp's platform functionality.

This may include:

* your telephone number;

* profile name;

* profile picture;

* messages;

* reactions; and

* other profile information.

WhatsApp/Meta also processes information under its own privacy terms.

You should assume that information voluntarily posted in a group community may be seen by other group participants.

Although Members are expected to respect confidentiality under the Agency Lab Terms of Use, we cannot guarantee that another Member will keep information you voluntarily share confidential.

Please use appropriate discretion.

13. MARKETING COMMUNICATIONS

We may send Agency Lab Members and prospective Members relevant marketing communications where permitted by law.

Marketing may relate to:

* Agency Lab;

* other Scale Certified services;

* training;

* templates;

* events;

* workshops;

* software;

* promotional offers; and

* other business products or services.

The lawful basis used will depend on the circumstances and applicable jurisdiction and may include consent or legitimate interests where permitted.

Every ordinary marketing email we send should provide a method to unsubscribe.

You can also request to stop receiving marketing by contacting: [email protected]

We may retain a limited suppression record after you unsubscribe so that we can remember and respect your preference.

YOU HAVE THE RIGHT TO OBJECT TO THE USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING WHERE APPLICABLE LAW PROVIDES THAT RIGHT.

14. SMS AND TELEPHONE NUMBERS

We do not ordinarily rely on SMS as a primary marketing channel for Agency Lab Members.

Telephone numbers may be collected and used for legitimate purposes including:

* account creation;

* two-factor authentication;

* identity verification;

* security;

* support;

* GoHighLevel account provisioning; and

* communications reasonably connected to your membership.

If we introduce additional SMS or telephone marketing activities, we will do so subject to applicable consent and marketing requirements.

15. COOKIES, PIXELS AND SIMILAR TECHNOLOGIES

Our websites and digital services may use cookies, pixels, tags, scripts and similar technologies.

These technologies may be used for:

* essential site functionality;

* authentication;

* security;

* remembering preferences;

* website analytics;

* performance measurement;

* attribution;

* conversion tracking;

* advertising;

* retargeting;

* audience creation; and

* improving our websites.

Technologies and providers currently or historically used may include:

* Meta Pixel;

* Google Analytics;

* Google Ads conversion and advertising technologies;

* GoHighLevel website and funnel technology; and

* similar analytics, advertising or marketing technologies.

We may introduce additional providers in the future, such as TikTok or other advertising and analytics platforms, where appropriate.

Where applicable law requires consent before a non-essential cookie, pixel or similar technology is placed or accessed, we will seek the required consent.

You may also be able to control cookies through available website consent controls and your browser/device settings.

Our use of cookies and advertising technologies may change as our marketing technology changes.

16. CUSTOM AUDIENCES, RETARGETING AND ADVERTISING PLATFORMS

Where permitted by applicable law, we may use advertising-platform tools to create or participate in:

* custom audiences;

* customer-match audiences;

* retargeting audiences;

* lookalike or similar audiences;

* conversion measurement; and

* advertising optimisation.

For example, we may provide an advertising platform with identifiers such as an email address in a hashed or otherwise platform-compatible format so the platform can determine whether an individual has an existing account with that platform.

We may use these tools to:

* advertise to existing leads or customers;

* advertise to individuals with similar characteristics;

* measure campaign effectiveness;

* exclude existing customers from acquisition advertising; or

* reconnect with individuals who previously interacted with Scale Certified.

Where consent or another specific legal requirement applies, we will use these tools subject to that requirement.

17. WHETHER WE SELL PERSONAL INFORMATION

We do not sell Agency Lab Members' personal information to third parties for money.

We also do not sell a Member's GoHighLevel client or prospect database.

However, certain privacy laws use terms such as “sale,” “sharing,” “targeted advertising” or “cross-context behavioural advertising” more broadly than an ordinary monetary sale.

For example, the use of certain advertising pixels, audience-matching technologies or advertising-platform disclosures may be treated as “sharing” or targeted advertising under some laws even where no money is paid for the information.

Where such laws apply, we will provide applicable choices or opt-out mechanisms as required.

18. TESTIMONIALS, REVIEWS AND MEMBER SUCCESS STORIES

We may use testimonials, reviews, feedback and Member success stories for legitimate promotional, educational and marketing purposes.

Depending on what you voluntarily provide or authorise, this may include:

* your name;

* business name;

* job title;

* photograph;

* profile image;

* written testimonial;

* screenshots;

* revenue or sales figures you voluntarily disclose;

* audio;

* voice;

* video; and

* other information associated with your result.

Where applicable law requires specific consent for a particular use, we will obtain that consent.

We may edit testimonials for formatting, spelling, length or clarity but should not intentionally alter them in a manner that materially misrepresents the Member's experience.

Testimonials and case studies do not constitute guarantees that other Members will obtain similar results.

19. WHO WE SHARE INFORMATION WITH

We may disclose personal information to service providers and other recipients where reasonably necessary to operate Agency Lab.

Categories of recipients may include:

19.1 GoHighLevel / HighLevel

For:

* CRM services;

* account provisioning;

* funnels and websites;

* automation;

* telecommunications;

* email;

* AI;

* account management;

* billing;

* forms;

* calendars; and

* other Agency Lab software functionality.

19.2 Payment Providers

Including:

* Stripe;

* PayPal in limited circumstances;

* Wise in limited circumstances; and

* other payment providers we may lawfully use in the future.

19.3 Google

Including services that may support:

* Google Meet;

* Google Workspace;

* email;

* document storage;

* meeting recordings;

* Gemini meeting notes;

* transcripts;

* analytics;

* advertising; and

* other business functions.

19.4 Meta

Including services such as:

* WhatsApp;

* Facebook;

* Instagram;

* Meta Pixel;

* advertising; and

* audience tools.

19.5 Email and Marketing Platforms

This may include providers such as MailerLite and other communications providers used from time to time.

19.6 Legacy Learning Platforms

Some legacy Agency Lab Members may have information stored within Teachable because historical Agency Lab content or access was provided through that platform.

19.7 Automation Providers

We may use providers such as Zapier to transmit information between authorised business systems and automate administrative processes.

19.8 Advertising and Analytics Providers

This may include:

* Google;

* Meta;

* and other advertising, analytics or measurement providers that we may use in the future.

19.9 Future Accounting and Financial Systems

We do not currently rely on an integrated accounting platform for Agency Lab in the manner described here.

We may introduce accounting, bookkeeping, tax, financial-management or invoicing systems in the future.

If introduced, relevant transaction and business information may be transferred to those providers where reasonably necessary for financial administration or legal compliance.

19.10 Professional Advisers

We may disclose information where necessary to:

* lawyers;

* accountants;

* tax advisers;

* insurance providers;

* auditors;

* consultants; and

* similar professional advisers.

19.11 Authorities and Legal Recipients

We may disclose information to:

* courts;

* regulators;

* law-enforcement authorities;

* tax authorities;

* government agencies; or

* other persons

where legally required or reasonably necessary to establish, exercise or defend legal rights.

19.12 Corporate Transactions

If all or part of our business is reorganised, merged, acquired, financed or sold, personal information may be disclosed to relevant professional advisers, counterparties or successor organisations subject to appropriate safeguards.

20. THIRD-PARTY PRIVACY POLICIES

Third-party platforms operate under their own agreements and privacy practices.

Depending on the circumstances, a third party may act as:

* our processor;

* our sub-processor;

* an independent controller;

* a joint controller; or

* a service provider.

This Privacy Policy does not replace the privacy policy of Google, HighLevel, Stripe, Meta, PayPal, Wise, Teachable, MailerLite, Zapier or another third-party service.

We encourage you to review the relevant provider's privacy information where appropriate.

21. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Agency Lab operates internationally and uses technology providers located in different countries.

As a result, personal information may be processed in countries outside the United Kingdom, including potentially:

* Canada;

* the United States;

* countries in the European Economic Area; and

* other jurisdictions in which our authorised service providers operate.

Some countries may have different data-protection laws from those that apply in the United Kingdom.

Where the UK rules on restricted international transfers apply, we use or rely on an appropriate lawful transfer mechanism where required.

Depending on the recipient and circumstances, this may include:

* UK adequacy regulations;

* the UK Extension to the EU-U.S. Data Privacy Framework where applicable to a participating recipient;

* the UK International Data Transfer Agreement;

* an approved UK Addendum to appropriate standard contractual clauses;

* another legally recognised contractual safeguard; or

* a permitted statutory exception where appropriate.

Where data is transferred to Canada, the availability of an adequacy-based transfer mechanism may depend on whether the recipient and relevant processing fall within the applicable Canadian legal framework.

You may contact us for further information about safeguards applicable to a particular transfer.

22. DATA RETENTION

We do not intend to retain identifiable personal information for longer than is reasonably necessary for the purpose for which it is held, subject to legal, contractual, accounting, security and dispute-resolution requirements.

Retention periods vary depending on the category of information.

22.1 Membership and Contract Records

Membership, subscription and contractual records may be retained for the duration of the relationship and afterwards for a reasonable period where necessary for:

* record keeping;

* disputes;

* contractual enforcement;

* fraud prevention;

* tax;

* accounting; or

* legal claims.

Certain relevant business records may be retained for approximately six years or longer where applicable law requires or permits.

22.2 Payment and Accounting Information

Transaction, invoice, billing and accounting records may generally be retained for the period required under applicable tax, accounting and corporate-record laws.

22.3 Marketing Information

Marketing information may be retained while you remain a relevant contact or until you opt out or we determine the information is no longer reasonably required.

Where you opt out, we may retain limited suppression information for as long as reasonably necessary to ensure we respect your preference.

22.4 Customer Support Records

Customer support and correspondence may be retained for as long as reasonably necessary to:

* support your account;

* maintain a history of technical issues;

* handle disputes;

* understand past decisions; and

* establish or defend legal claims.

22.5 Coaching Recordings

Coaching recordings, transcripts and notes may be retained for as long as they remain part of the Agency Lab educational, replay or training library or another legitimate purpose continues to apply.

22.6 AI Conversations

Agency Lab AI conversations, summaries and associated information may be retained while reasonably necessary to provide and improve the internal AI Agent, maintain support records, identify Knowledge Base gaps and fulfil related legitimate purposes, subject to the retention functionality and terms of the underlying GoHighLevel platform.

22.7 GoHighLevel Member and Client Data

Personal information stored within Agency Lab GoHighLevel accounts is also subject to the Agency Lab Terms of Use, the Scale Certified GoHighLevel Terms of Use and applicable HighLevel platform retention processes.

When an Agency Lab membership ends, provisioned GoHighLevel accounts and client sub-accounts are subject to closure and deletion as described in the applicable Terms.

Members are responsible for exporting information they are entitled and technically able to retain before their accounts are deleted.

22.8 Legal Holds

Information may be retained for longer than our ordinary retention period where necessary because of:

* litigation;

* a regulatory investigation;

* a tax inquiry;

* fraud;

* a payment dispute;

* a legal hold;

* an outstanding complaint; or

* another legal obligation.

When information is no longer required, we may delete or anonymise it.

23. INFORMATION SECURITY

We use reasonable technical and organisational measures designed to protect personal information against:

* unauthorised access;

* unauthorised disclosure;

* accidental loss;

* misuse;

* alteration; and

* destruction.

Depending on the system and information involved, measures may include:

* access controls;

* password protection;

* authentication measures;

* encryption provided by our technology providers;

* role-based permissions;

* secure payment providers;

* staff access restrictions;

* security monitoring; and

* third-party security infrastructure.

However, no internet transmission, cloud system, software platform or electronic storage method can be guaranteed to be completely secure.

Members are also responsible for protecting their own passwords, devices and account credentials.

24. DATA BREACHES

If we become aware of a personal-data breach affecting information for which we are responsible, we will investigate and respond in accordance with applicable data-protection requirements.

Where legally required, we will notify:

* the appropriate supervisory authority;

* affected individuals; and/or

* relevant Agency Lab Members

within the applicable legal timeframe.

Where we are acting as a processor on behalf of a Member, our obligations may instead include notifying and assisting the relevant Member in accordance with applicable data-processing terms.

25. YOUR UK DATA PROTECTION RIGHTS

Depending on the circumstances and lawful basis used, individuals protected by UK data-protection law may have rights including:

25.1 Right of Access

You may have the right to request confirmation of whether we process your personal information and obtain a copy of information we hold about you.

25.2 Right to Rectification

You may ask us to correct inaccurate personal information or complete information that is incomplete.

25.3 Right to Erasure

In certain circumstances, you may ask us to delete personal information.

This right is not absolute.

We may retain information where necessary for purposes such as:

* legal obligations;

* accounting;

* contractual records;

* fraud prevention;

* exercising or defending legal claims; or

* another lawful reason.

25.4 Right to Restrict Processing

In certain circumstances, you may request that we restrict how personal information is processed.

25.5 Right to Data Portability

Where applicable, you may have the right to receive certain information you provided in a structured, commonly used and machine-readable format or request its transfer to another controller.

25.6 Right to Object

Where we process information based on legitimate interests, you may have the right to object based on your particular circumstances.

DIRECT MARKETING

YOU MAY OBJECT TO THE PROCESSING OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING PURPOSES AT ANY TIME.

You can normally do this by clicking the unsubscribe link in a marketing email or by contacting: [email protected]

25.7 Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent at any time.

25.8 Automated Decision-Making

You may have rights relating to certain decisions made solely by automated means where they produce legal or similarly significant effects.

As of the Effective Date, we do not ordinarily use Agency Lab personal information to make solely automated decisions of this nature.

26. HOW TO EXERCISE YOUR PRIVACY RIGHTS

To request access, correction, deletion, restriction, objection, portability or another applicable privacy right, contact: [email protected]

Please clearly identify that your request relates to privacy or data protection.

We may request reasonable information necessary to:

* verify your identity;

* confirm your authority;

* locate the relevant information; and

* protect information from unauthorised disclosure.

Where a request relates to information controlled by an Agency Lab Member rather than by Scale Certified, we may direct the request to the relevant Member or assist them as required by applicable processing obligations.

We will respond in accordance with applicable law.

27. COMPLAINTS TO THE ICO

If you are located in the United Kingdom and are dissatisfied with how we handle your personal information, we encourage you to contact us first so that we can attempt to resolve your concern.

You also have the right to raise an appropriate complaint with the UK's data-protection regulator:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

United Kingdom

Telephone: 0303 123 1113

Individuals outside the United Kingdom may also have the right to complain to the appropriate data-protection or privacy regulator in their own jurisdiction.

28. EEA RIGHTS

Where the EU GDPR applies to our processing, individuals may have rights corresponding to those described above, including rights of:

* access;

* correction;

* erasure;

* restriction;

* portability;

* objection;

* withdrawal of consent; and

* complaint to an applicable EEA supervisory authority.

Rights are subject to the conditions and exceptions contained in applicable law.

29. CANADIAN PRIVACY RIGHTS

Individuals in Canada may have rights under applicable federal or provincial privacy legislation.

Depending on the applicable law, those rights may include rights to:

* understand how personal information is used;

* access personal information;

* correct inaccurate information;

* withdraw certain consent; and

* raise a complaint.

Requests may be sent to: [email protected]

30. UNITED STATES PRIVACY RIGHTS

Residents of certain United States jurisdictions may have additional privacy rights where the relevant state law applies to our processing.

Depending on applicable law, these may include rights to request:

* access to personal information;

* categories of personal information collected;

* correction;

* deletion;

* portability;

* information about disclosures;

* opt-out of sale;

* opt-out of certain forms of sharing;

* opt-out of targeted advertising;

* opt-out of certain profiling; and

* appeal of certain privacy decisions.

Not every right applies in every state or circumstance.

We will honour applicable rights where the relevant law applies to our processing.

As stated above, we do not sell personal information for monetary consideration.

Certain advertising activities may nevertheless qualify as “sharing,” targeted advertising or similar processing under some US privacy laws.

To exercise an applicable privacy right, contact: [email protected]

31. SPECIAL-CATEGORY AND SENSITIVE PERSONAL INFORMATION

Agency Lab generally does not require special-category or highly sensitive personal information in order to provide the membership.

Please avoid unnecessarily providing information regarding:

* racial or ethnic origin;

* political opinions;

* religious or philosophical beliefs;

* trade-union membership;

* genetic data;

* biometric identification;

* health information;

* sex life or sexual orientation;

* criminal-offence information;

* government identification documents;

* passwords;

* financial-account credentials; or

* other highly sensitive information.

If such information is voluntarily provided, we will process it only where a lawful basis and, where applicable, an additional condition for processing exists.

32. CHILDREN'S PRIVACY

Agency Lab is a business service intended for individuals aged eighteen (18) and over.

We do not knowingly offer Agency Lab to children.

If you believe a child has directly provided us with personal information inappropriately, please contact: [email protected]

33. THIRD-PARTY LINKS

Agency Lab websites, training or community resources may contain links to third-party websites, services or platforms.

We do not control the privacy practices of independent third parties.

When you leave our environment or use a separately controlled third-party service, that provider's privacy terms may apply.

34. CHANGES TO SERVICE PROVIDERS

The technology used to operate Agency Lab may evolve.

We may:

* replace service providers;

* add new providers;

* stop using existing providers;

* change learning platforms;

* change community platforms;

* introduce new advertising platforms;

* introduce accounting software;

* introduce new analytics tools;

* adopt new AI providers; or

* make other changes to our technology stack.

We will review and update this Privacy Policy where a material change to our processing requires updated privacy information.

The fact that a category of future service provider is identified in this Policy does not remove any requirement to obtain consent or satisfy another legal requirement where applicable.

35. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

* changes to Agency Lab;

* changes in our processing;

* new technologies;

* new service providers;

* changes to advertising;

* changes to AI functionality;

* legal requirements;

* regulatory guidance;

* security requirements; or

* improvements to transparency.

The revised Policy will show an updated effective or revision date.

Where legally required or where a change is particularly significant, we may also notify Members by email, through the Content Portal or by another appropriate method.

36. RELATIONSHIP WITH THE AGENCY LAB TERMS

This Privacy Policy explains how personal information is handled.

The Agency Lab Terms of Use separately govern the contractual relationship between Agency Lab and its Members.

The Scale Certified GoHighLevel Terms of Use separately govern important aspects of GoHighLevel accounts provisioned through Agency Lab, including account operation, usage charges, suspension, termination and deletion.

Where applicable, separate data-processing terms may govern personal information that Scale Certified processes on behalf of an Agency Lab Member.

37. CONTACT US

For questions about this Privacy Policy, our privacy practices, personal information we hold or an applicable data-protection request, contact:

6IX Media Group Limited

Trading as Scale Certified

Company Number: SC650838

Email: [email protected]

Please include “Privacy Request” or “Data Protection Request” in your subject line where appropriate so that your request can be identified and handled efficiently.

38. ACKNOWLEDGMENT

By using Agency Lab, you acknowledge that personal information may be processed as described in this Privacy Policy, subject to your rights and the requirements of applicable data-protection law.

In particular, Agency Lab Members should understand that:

1. Agency Lab is operated by 6IX Media Group Limited under the Scale Certified brand;

2. Scale Certified Inc. may process payment and administrative information on behalf of 6IX Media Group Limited;

3. Agency Lab uses third-party technology providers including GoHighLevel, Stripe, Google and Meta;

4. information may be processed outside the United Kingdom;

5. Agency Lab coaching calls and workshops may be recorded, transcribed and made available as Member training content;

6. participation in the WhatsApp community may expose certain profile and contact information to other Members;

7. interactions with the internal Agency Lab AI Agent are stored within GoHighLevel and may be reviewed by authorised personnel;

8. AI conversations may be used to identify Knowledge Base gaps and improve Agency Lab support and resources;

9. Scale Certified may have administrative access to GoHighLevel accounts and the data stored within them;

10. Agency Lab Members remain responsible for the privacy and legal compliance of personal data relating to their own clients, customers, leads and prospects;

11. Scale Certified does not use a Member's client or prospect database for Scale Certified's own marketing;

12. Scale Certified does not sell personal information for monetary consideration;

13. advertising cookies, pixels and audience technologies may be used subject to applicable privacy and consent requirements; and

14. privacy and data-protection requests should be sent to [email protected].