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 when you interact with Scale Certified, purchase or use our products and services, visit our websites, communicate with us, participate in our communities or otherwise engage with our business.

We are committed to handling personal information responsibly, transparently and in accordance with applicable privacy and data protection laws.

This Privacy Policy applies broadly across Scale Certified websites, sales pages, products, services and offers unless a separate or supplemental privacy notice expressly applies to a particular service.

1. WHO WE ARE

The primary data controller responsible for personal information collected through Scale Certified is:

6IX Media Group Limited

Company Number: SC650838

Email: [email protected]

6IX Media Group Limited is registered in Scotland and operates the Scale Certified brand.

Scale Certified Inc., a Canadian corporation, acts as a payment-processing and administrative representative for 6IX Media Group Limited and may process personal information on its behalf in connection with payments, billing, account administration and related business operations.

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

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2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed in connection with Scale Certified offerings and activities, which may include:

* websites;

* landing pages;

* sales pages;

* checkout pages;

* digital products;

* template packs;

* snapshots;

* courses;

* training programmes;

* memberships;

* recurring subscriptions;

* trials;

* software access;

* GoHighLevel accounts or services;

* artificial intelligence tools;

* coaching;

* workshops;

* webinars;

* live calls;

* communities;

* downloadable resources;

* lead magnets;

* forms;

* quizzes;

* calendars and appointments;

* customer support;

* email communications;

* advertising;

* promotions;

* testimonials;

* surveys;

* affiliate or referral activity where applicable; and

* other products or services offered under the Scale Certified brand.

We may provide additional privacy information for a particular service where the nature of that service requires additional disclosure.

If a supplemental privacy notice applies to a particular service, that notice should be read together with this Privacy Policy.

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3. PERSONAL INFORMATION WE COLLECT

The information we collect depends on how you interact with Scale Certified.

We may collect the following categories of personal information.

3.1 Identity Information

This may include:

* first name;

* last name;

* username;

* account identifier;

* business representative information; and

* other information used to identify you or your account.

3.2 Contact Information

This may include:

* email address;

* telephone number;

* business address;

* mailing address;

* country;

* region;

* postcode or ZIP code; and

* other contact information you voluntarily provide.

Certain software services or account-provisioning processes may require additional business or location information.

3.3 Business Information

Because many Scale Certified services are designed for business owners, agencies, marketers and entrepreneurs, we may collect information such as:

* business name;

* trading name;

* industry;

* niche;

* business website;

* business address;

* business telephone number;

* business email address;

* services offered;

* business size;

* business goals;

* client information you voluntarily discuss with us;

* software configuration;

* account requirements; and

* other information relevant to the service you request.

3.4 Account and Service Information

Depending on the product or service, we may collect:

* login information;

* account status;

* course access;

* subscription status;

* purchase history;

* trial information;

* payment-plan information;

* pause information;

* cancellation information;

* grandfathered pricing information;

* software-account information;

* support history;

* account permissions;

* resource usage;

* course activity; and

* other information necessary to administer your relationship with us.

3.5 Payment and Transaction Information

We may collect information relating to:

* purchases;

* subscription payments;

* trial payments;

* renewal payments;

* usage charges;

* invoices;

* transaction dates;

* payment status;

* currency;

* taxes;

* failed payments;

* refunds where applicable;

* payment disputes;

* chargebacks;

* billing history; and

* payment method type.

Our primary payment processor is Stripe.

In limited circumstances, we may use other providers such as PayPal or Wise.

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

Payment credentials are generally collected and stored by the applicable payment processor.

Where payment methods are connected to software services such as GoHighLevel, payment credentials may be stored and processed through Stripe, HighLevel or another authorised payment provider.

3.6 Technical and Device Information

When you use our websites or online services, we and our technology providers may automatically collect information including:

* IP address;

* browser;

* browser version;

* device type;

* operating system;

* language;

* device identifiers;

* referring URL;

* pages visited;

* time and date of visits;

* session information;

* login activity;

* approximate location derived from technical information;

* cookie identifiers;

* advertising identifiers;

* interaction data; and

* similar technical information.

3.7 Communications and Support Information

When you communicate with us, we may retain information including:

* emails;

* support requests;

* questions;

* complaints;

* troubleshooting information;

* account requests;

* screenshots;

* attachments;

* chat conversations;

* messages;

* call notes;

* WhatsApp communications; and

* other correspondence.

Communications may generally be retained within the platform through which they took place or within another authorised business system where required for support, record keeping or administration.

3.8 Form, Survey and Application Information

Where you complete a Scale Certified form, questionnaire, survey, quiz, intake form or application, we may collect the information you voluntarily submit.

The exact information collected will depend on the purpose of the form.

3.9 Community Information

Where a Scale Certified product or membership includes access to a community, we may process:

* your name;

* profile information;

* telephone number where relevant to the community platform;

* profile photograph;

* messages;

* posts;

* reactions;

* comments;

* questions;

* voice notes;

* files;

* business information; and

* other information you voluntarily share.

3.10 Live Call, Webinar and Recording Information

Certain Scale Certified products may include:

* coaching calls;

* workshops;

* webinars;

* group sessions;

* onboarding calls;

* demonstrations;

* training calls; or

* similar live sessions.

These sessions may be recorded.

Depending on how you participate, recordings may contain:

* your name;

* voice;

* image;

* questions;

* comments;

* screen share;

* chat messages;

* business information; and

* other contributions.

We currently use services including Google Meet for certain live sessions.

Google Gemini or similar artificial intelligence functionality may be used to generate meeting:

* transcripts;

* summaries;

* notes;

* action items; and

* other meeting-related information.

3.11 Artificial Intelligence Interaction Information

Some Scale Certified services include or interact with artificial intelligence tools.

Where you use an AI tool made available through one of our Services, we may process:

* prompts;

* questions;

* messages;

* conversation history;

* AI-generated responses;

* feedback;

* summaries;

* uploaded information;

* usage information; and

* other information contained in your interaction.

Depending on the particular tool, AI interactions may be stored by Scale Certified and/or the underlying technology provider.

Authorised Scale Certified personnel may review AI interactions where reasonably necessary to:

* provide support;

* investigate problems;

* improve AI performance;

* identify frequently asked questions;

* identify Knowledge Base gaps;

* improve training;

* improve resources;

* understand product usage; or

* improve the relevant service.

3.12 Marketing and Advertising Information

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

* emails opened;

* links clicked;

* advertisements viewed;

* advertisements clicked;

* forms submitted;

* pages visited;

* purchase attribution;

* referral source;

* marketing preferences;

* advertising identifiers;

* campaign information; and

* audience information.

3.13 Testimonials, Reviews and Results

If you voluntarily provide a testimonial, review, feedback, case study or success story, we may collect:

* your name;

* business name;

* business results;

* written comments;

* screenshots;

* profile photograph;

* photograph;

* voice;

* video;

* revenue or sales information you voluntarily disclose; and

* other information associated with your testimonial.

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4. HOW WE COLLECT PERSONAL INFORMATION

We may collect information in several ways.

4.1 Directly From You

For example when you:

* visit our website;

* submit a form;

* purchase a product;

* begin a trial;

* subscribe to a service;

* create an account;

* request software access;

* request a sub-account;

* schedule a call;

* attend a workshop;

* contact support;

* send an email;

* join a community;

* use an AI tool;

* submit a testimonial;

* participate in a survey; or

* otherwise communicate with us.

4.2 Automatically

Information may be automatically collected through:

* cookies;

* pixels;

* analytics;

* tracking technologies;

* server logs;

* advertising tools;

* email tracking;

* website technology; and

* similar systems.

4.3 From Service Providers

We may receive information from providers involved in operating our business, including:

* payment processors;

* CRM providers;

* software providers;

* course platforms;

* email platforms;

* advertising platforms;

* analytics providers;

* authentication providers;

* community platforms; and

* other authorised service providers.

4.4 From Referral or Affiliate Sources

Where applicable, we may receive information indicating that you were referred to us through:

* an affiliate;

* referral partner;

* advertisement;

* campaign;

* promotional link; or

* other marketing source.

4.5 From Publicly Available Sources

Where lawful and appropriate, we may process information that has been made publicly available, including information voluntarily published on business websites, social media, public reviews or other public sources.

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5. HOW WE USE PERSONAL INFORMATION

We may use personal information for purposes including the following.

5.1 Providing Products and Services

We may process information to:

* complete purchases;

* deliver digital products;

* provide download or import links;

* create accounts;

* provide software access;

* grant course access;

* deliver memberships;

* provide templates;

* provide communities;

* provide AI tools;

* administer subscriptions;

* provide live sessions;

* provide bonuses;

* fulfil orders;

* authenticate users; and

* otherwise deliver the product or service purchased or requested.

5.2 Processing Payments

We may process information to:

* collect payments;

* administer recurring subscriptions;

* process trials;

* process usage charges;

* administer payment plans;

* identify failed payments;

* process taxes;

* maintain transaction records;

* investigate billing issues;

* prevent payment fraud; and

* respond to payment disputes or chargebacks.

5.3 Customer Support

We may process information to:

* respond to questions;

* provide account support;

* provide basic technical support;

* troubleshoot;

* investigate reported issues;

* provision accounts;

* manage access;

* process cancellations;

* process pauses;

* investigate billing issues; and

* otherwise assist customers.

5.4 Service Administration

We may process information to:

* administer accounts;

* manage subscriptions;

* provide security;

* maintain records;

* communicate product updates;

* manage access;

* maintain communities;

* manage software;

* organise workshops or calls; and

* operate Scale Certified.

5.5 Improving Products and Services

We may use information to:

* understand how products are used;

* identify common questions;

* improve our Knowledge Bases;

* improve training;

* develop new products;

* improve templates;

* improve software configurations;

* improve AI tools;

* improve support;

* understand customer needs;

* analyse product performance; and

* improve the customer experience.

5.6 Security and Fraud Prevention

We may process information to:

* verify identities;

* support two-factor authentication;

* secure accounts;

* detect suspicious activity;

* prevent unauthorised access;

* prevent fraud;

* protect payment systems;

* investigate misuse;

* enforce contractual terms; and

* protect Scale Certified, our customers and third parties.

5.7 Operational Communications

We may send communications relating to:

* purchases;

* account access;

* order delivery;

* payments;

* subscriptions;

* account security;

* workshops;

* software;

* support;

* service changes;

* policy changes; and

* other matters necessary to administer your relationship with us.

These operational messages are different from optional marketing communications.

5.8 Marketing

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

* Scale Certified products;

* memberships;

* software;

* courses;

* template packs;

* workshops;

* events;

* promotions;

* special offers;

* new products;

* upgrades; and

* related services.

You may unsubscribe from ordinary marketing emails at any time by using the unsubscribe link at the bottom of the email.

You may also contact: [email protected]

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

5.9 Advertising

Subject to applicable law and consent requirements, we may process information to:

* measure advertising performance;

* attribute purchases;

* create advertising audiences;

* retarget website visitors;

* create customer-match audiences;

* create similar or lookalike audiences;

* suppress existing customers from campaigns;

* personalise advertising;

* measure conversions; and

* improve advertising campaigns.

5.10 Legal and Regulatory Purposes

We may process information where necessary to:

* comply with law;

* maintain financial and corporate records;

* comply with tax obligations;

* respond to lawful authorities;

* prevent unlawful conduct;

* establish or defend legal claims;

* enforce agreements; and

* protect our legal rights.

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6. LAWFUL BASES FOR PROCESSING

Where applicable law requires a lawful basis, the basis we rely on will depend on the purpose of the processing.

6.1 Contract

We may process information where necessary to enter into or perform a contract with you.

This may include:

* processing your purchase;

* creating your account;

* providing your product;

* providing software;

* providing membership access;

* administering a subscription; and

* providing support connected to your purchase.

6.2 Legitimate Interests

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

Our legitimate interests may include:

* operating Scale Certified;

* administering customer relationships;

* improving our products;

* understanding our customers;

* maintaining records;

* securing our systems;

* preventing fraud;

* developing products;

* improving support;

* improving AI and Knowledge Base resources;

* protecting our business;

* enforcing contracts;

* measuring business performance; and

* promoting relevant products where permitted by law.

6.3 Consent

We may rely on consent for processing such as:

* certain marketing communications;

* non-essential cookies;

* advertising technologies;

* certain testimonial uses;

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

* other activities where consent is required.

Where processing relies upon your consent, you may withdraw that consent.

6.4 Legal Obligation

We may process information where required to comply with:

* tax requirements;

* accounting obligations;

* corporate requirements;

* regulatory requirements;

* lawful requests; or

* other legal obligations.

6.5 Legal Claims

We may process or retain relevant information where necessary to establish, exercise or defend legal rights or claims.

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7. CUSTOMER, CLIENT AND PROSPECT DATA PROCESSED THROUGH OUR SOFTWARE SERVICES

Certain Scale Certified products may provide, provision, host, manage or support software through which our customers process information belonging to their own clients, customers, prospects or leads.

This is different from the personal information Scale Certified collects about its own customers.

7.1 Customer-Controlled Information

Where a Scale Certified customer uses software made available through us to upload or collect information about their own:

* clients;

* customers;

* prospects;

* leads;

* employees;

* contractors;

* website visitors; or

* other contacts,

the Scale Certified customer will ordinarily determine why and how that information is processed.

The customer will therefore ordinarily act as the controller of that information.

Where the customer itself processes information for one of its clients, the customer may instead be acting as a processor.

7.2 Scale Certified's Role

Where Scale Certified hosts, provisions, administers or accesses that software solely to:

* provide the service;

* provision accounts;

* install permitted systems;

* maintain the platform;

* provide technical support;

* troubleshoot;

* maintain security; or

* follow the customer's instructions,

Scale Certified will ordinarily act as a processor or service provider in relation to the relevant customer-controlled information.

Where our customer is itself a processor, Scale Certified may act as a sub-processor.

7.3 Administrative Access

Where we provision or administer software accounts, authorised Scale Certified personnel may technically have administrative access to information stored within those accounts.

We may access that information where reasonably necessary for authorised operational purposes including:

* technical support;

* troubleshooting;

* provisioning;

* security;

* account administration;

* investigating issues;

* billing support; or

* compliance with legal obligations.

7.4 We Do Not Use Customer Client Lists for Our Own Marketing

Scale Certified does not use customer-controlled client, lead or prospect databases stored within customer software accounts to independently market Scale Certified products to those contacts.

Our marketing is directed to Scale Certified's own customers, prospects, leads and audiences obtained through our own marketing activities.

7.5 Customer Responsibilities

Customers using Scale Certified software services remain responsible for:

* determining their lawful basis;

* maintaining their own privacy policy;

* providing required privacy notices;

* obtaining required consent;

* respecting data subject rights;

* obtaining permission to upload or process personal information;

* complying with communications laws;

* maintaining appropriate client agreements; and

* ensuring that their use of personal information complies with applicable law.

This Privacy Policy does not replace a customer's own privacy policy.

7.6 Data Processing Agreements

Where applicable law requires a controller-to-processor agreement, additional data-processing terms or a Data Processing Addendum may apply.

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8. GOHIGHLEVEL AND OTHER THIRD-PARTY SOFTWARE

Certain Scale Certified products or services may include, integrate with or provide access to GoHighLevel/HighLevel or other third-party software.

Those providers may process personal information as:

* our processors;

* our sub-processors;

* independent controllers; or

* service providers,

depending on the circumstances.

Where you use a third-party platform, information may also be processed in accordance with that platform's own privacy policy, terms and data-processing arrangements.

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9. ARTIFICIAL INTELLIGENCE

9.1 Use of AI

Scale Certified products, websites, courses or software may incorporate artificial intelligence.

AI may be used for purposes including:

* answering questions;

* customer support;

* generating content;

* automation;

* analysis;

* call transcription;

* call summaries;

* Knowledge Base assistance;

* voice systems;

* chat systems;

* workflow assistance; and

* other product functionality.

9.2 AI Conversations

Depending on the service, AI conversations may be:

* stored;

* logged;

* summarised;

* reviewed by authorised personnel;

* analysed to improve our Knowledge Base;

* analysed to identify recurring questions;

* used to troubleshoot responses; or

* used to improve the relevant Scale Certified service.

9.3 Third-Party AI Providers

AI functionality may rely on third-party platforms or models.

Those providers may process information as necessary to provide contracted AI functionality and in accordance with their applicable privacy and data-processing terms.

Scale Certified does not intentionally provide customer information to third-party foundation-model providers for the independent purpose of training unrelated general-purpose AI models unless this is separately disclosed or authorised.

9.4 Sensitive Information and AI

Do not unnecessarily submit highly sensitive or confidential information to AI systems.

In particular, avoid submitting:

* complete card details;

* passwords;

* authentication codes;

* government identification numbers;

* sensitive medical information;

* biometric information;

* criminal-offence information;

* confidential client data that is not necessary; or

* other special-category or highly sensitive information.

You remain responsible for information you voluntarily submit to an AI tool.

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10. RECORDED CALLS, TRAINING AND WORKSHOPS

Certain Scale Certified services may include calls, coaching sessions, webinars or workshops that are recorded.

Recording may capture:

* your name;

* image;

* voice;

* questions;

* comments;

* screen shares;

* chat messages; and

* information you voluntarily discuss.

Artificial intelligence functionality such as Google Gemini may also be used to produce:

* transcripts;

* summaries;

* meeting notes;

* action items; and

* similar meeting records.

Recordings may be:

* made available as replays;

* added to training portals;

* incorporated into course libraries;

* used for internal training;

* retained as educational resources;

* used to improve products; or

* retained where reasonably necessary for legitimate business purposes.

Where recordings are made available to other customers or members, your contribution may be visible or audible to those individuals.

Please exercise discretion before sharing sensitive, confidential or client-specific information during group sessions.

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11. COMMUNITIES AND SOCIAL PLATFORMS

Certain offers may include access to communities hosted on third-party platforms such as WhatsApp or another community provider.

Depending on the platform, other participants may be able to see:

* your name;

* phone number;

* profile photograph;

* profile information;

* posts;

* comments;

* messages; and

* other information you voluntarily share.

The platform provider will also process information under its own privacy terms.

Although community rules may require participants to respect confidentiality, Scale Certified cannot guarantee that another community participant will keep information you voluntarily disclose confidential.

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12. MARKETING EMAILS AND COMMUNICATIONS

Where permitted by law, we may communicate with individuals who:

* purchase from us;

* request information;

* submit a lead form;

* subscribe to our communications;

* register for an event;

* download a resource;

* interact with our offers; or

* otherwise establish a relevant relationship with Scale Certified.

Marketing communications may include information about:

* products;

* services;

* memberships;

* software;

* courses;

* template packs;

* promotions;

* events;

* workshops;

* updates; and

* related Scale Certified offers.

You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in the email.

You may also contact: [email protected]

We may retain limited suppression information after an opt-out so we can remember and respect your preference.

Where applicable, you have the right to object to direct marketing at any time.

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13. TELEPHONE NUMBERS, SMS AND AUTHENTICATION

Telephone numbers may be collected for purposes including:

* account setup;

* customer support;

* two-factor authentication;

* identity or account security;

* appointment booking;

* service communications;

* software provisioning; and

* other legitimate operational purposes.

Scale Certified does not ordinarily rely on SMS as its primary marketing channel.

Where we send marketing by SMS, telephone or another regulated communications channel, we will do so subject to applicable legal requirements and consent requirements.

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14. COOKIES, PIXELS AND TRACKING TECHNOLOGY

Scale Certified websites may use:

* cookies;

* tracking pixels;

* tags;

* scripts;

* analytics;

* advertising identifiers; and

* similar technologies.

These technologies may be used for:

* essential website functionality;

* security;

* remembering preferences;

* analytics;

* website performance;

* attribution;

* conversion measurement;

* advertising;

* retargeting;

* audience creation; and

* marketing optimisation.

Providers currently or historically used may include:

* Meta Pixel;

* Google Analytics;

* Google Ads;

* GoHighLevel tracking technologies; and

* other advertising or analytics providers.

We may introduce additional providers in the future, including platforms such as TikTok or comparable advertising services.

Where applicable law requires consent before non-essential tracking technology is used, we will seek the required consent.

Cookie and advertising preferences may also be controlled using available website consent tools and applicable browser or device settings.

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15. ADVERTISING, RETARGETING AND CUSTOM AUDIENCES

Where permitted by law, Scale Certified may use advertising tools including:

* custom audiences;

* customer matching;

* retargeting;

* lookalike audiences;

* similar audiences;

* conversion tracking; and

* campaign optimisation.

We may provide certain identifiers to advertising providers, such as an email address in a hashed or platform-compatible form, to determine whether an individual has an account with that platform.

These tools may be used to:

* advertise to existing leads;

* advertise to customers;

* reconnect with website visitors;

* identify audiences likely to be interested in Scale Certified;

* exclude existing customers from certain advertisements;

* measure conversions; and

* optimise advertising.

Where applicable law requires consent or provides an opt-out right, we will apply those requirements.

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16. SALE AND SHARING OF PERSONAL INFORMATION

Scale Certified does not sell personal information to third parties for monetary consideration.

We do not sell customer-controlled GoHighLevel contact lists or similar customer databases.

However, certain laws define terms such as:

* “sale”;

* “sharing”;

* “targeted advertising”; or

* “cross-context behavioural advertising”

more broadly than an ordinary sale for money.

For example, disclosures to advertising platforms through pixels, custom audiences or targeted advertising technologies may qualify as regulated “sharing” under certain laws.

Where applicable, we will provide legally required choices or opt-out mechanisms.

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17. TESTIMONIALS AND CASE STUDIES

Where you voluntarily provide or authorise a testimonial, review, success story or case study, we may use information including:

* your name;

* business name;

* title;

* photograph;

* profile photograph;

* written comments;

* screenshots;

* voice;

* video;

* results;

* sales or revenue information voluntarily disclosed; and

* related information.

Testimonials may be used for:

* websites;

* sales pages;

* advertisements;

* emails;

* social media;

* presentations;

* case studies; and

* other legitimate promotional purposes.

Where applicable law requires specific consent for a particular use of your personal information, image or likeness, we will obtain it.

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

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18. SERVICE PROVIDERS AND OTHER RECIPIENTS

We may disclose information to organisations that help us operate Scale Certified.

The particular providers involved depend on the product or service.

Categories and examples may include:

18.1 CRM and Software Providers

Such as:

* GoHighLevel/HighLevel; and

* other software providers used to deliver Scale Certified services.

18.2 Payment Providers

Such as:

* Stripe;

* PayPal;

* Wise; and

* other authorised payment providers.

18.3 Google Services

Google services may support functions including:

* Google Meet;

* Google Workspace;

* email;

* storage;

* Gemini;

* transcripts;

* meeting notes;

* Google Analytics;

* Google Ads; and

* other business functions.

18.4 Meta Services

Meta services may include:

* WhatsApp;

* Facebook;

* Instagram;

* Meta Pixel;

* advertising;

* audience tools; and

* related services.

18.5 Email Providers

We may use services including MailerLite, GoHighLevel and other email or communications providers.

18.6 Course and Learning Platforms

Certain current or legacy products may use platforms including Teachable or GoHighLevel.

18.7 Automation Providers

We may use platforms such as Zapier, GoHighLevel, or similar automation technology to transfer information between authorised business systems.

18.8 Analytics and Advertising Providers

We may share relevant information with authorised:

* analytics providers;

* advertising providers;

* conversion-measurement providers; and

* marketing technology platforms.

18.9 Hosting and Technology Providers

Personal information may be processed by providers supplying:

* website hosting;

* cloud services;

* security;

* databases;

* file storage;

* email;

* telecommunications; and

* technical infrastructure.

18.10 Accounting and Financial Providers

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

Relevant transaction and business information may be processed through those systems where required for:

* accounting;

* taxation;

* reconciliation;

* reporting;

* invoicing; or

* financial administration.

18.11 Professional Advisers

Information may be disclosed where appropriate to:

* lawyers;

* accountants;

* tax advisers;

* insurers;

* auditors;

* consultants; and

* other professional advisers.

18.12 Authorities

We may disclose personal information where required or legally permitted to:

* courts;

* regulators;

* tax authorities;

* government bodies;

* law-enforcement authorities; or

* other legally authorised recipients.

18.13 Business Transfers

If Scale Certified or a relevant part of its business is:

* sold;

* merged;

* acquired;

* financed;

* reorganised; or

* transferred,

relevant personal information may be disclosed to advisers, counterparties or successor organisations subject to appropriate safeguards.

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19. THIRD-PARTY SERVICES

Third-party providers have their own privacy and data-processing practices.

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

* our processor;

* our sub-processor;

* an independent controller;

* a joint controller; or

* another form of service provider.

This Privacy Policy does not replace the privacy policies of third-party providers.

We encourage you to review the privacy information supplied by relevant third-party platforms where appropriate.

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20. INTERNATIONAL DATA TRANSFERS

Scale Certified operates internationally and uses providers located in multiple jurisdictions.

Personal information may therefore be processed outside the United Kingdom, including potentially in:

* Canada;

* the United States;

* the European Economic Area; and

* other jurisdictions where authorised providers operate.

Where UK international-transfer rules apply, we will use an appropriate transfer mechanism where required.

Depending on the recipient and circumstances, this may include:

* UK adequacy regulations;

* an applicable approved data-privacy framework;

* the UK International Data Transfer Agreement;

* the UK Addendum to appropriate standard contractual clauses;

* another recognised contractual safeguard; or

* a legally permitted exception.

Where required, additional assessments and safeguards may also be implemented.

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21. DATA RETENTION

We retain identifiable personal information only for as long as reasonably necessary for the purpose for which it is held, taking account of:

* contractual requirements;

* tax requirements;

* accounting requirements;

* legal obligations;

* security;

* dispute resolution;

* fraud prevention;

* regulatory requirements; and

* legitimate business needs.

Retention periods vary by category.

21.1 Customer and Contract Records

Customer, subscription and contractual records may be retained throughout the relationship and for an appropriate period afterwards for:

* legal claims;

* contractual records;

* dispute resolution;

* tax;

* accounting;

* fraud prevention; and

* business administration.

Relevant records may commonly need to be retained for approximately six years or another period required by applicable law.

21.2 Payment Records

Billing, invoice and payment records may be retained for the period required under applicable:

* tax;

* accounting;

* corporate; and

* financial-record requirements.

21.3 Marketing Information

Marketing information may be retained while:

* you remain a customer or relevant prospect;

* the information remains reasonably useful for the purpose collected; or

* until you opt out.

After opting out, limited suppression information may be retained so that your marketing preference can continue to be respected.

21.4 Customer Support

Support information may be retained for a reasonable period to:

* maintain account history;

* understand previous technical issues;

* handle disputes;

* maintain customer-service records; and

* establish or defend legal claims.

21.5 Recordings

Recordings, transcripts, notes and related educational material may be retained for as long as they continue to form part of:

* a product;

* training library;

* membership;

* replay library;

* course;

* internal training resource; or

* another legitimate business purpose.

21.6 AI Conversations

AI interactions may be retained for as long as reasonably necessary to:

* provide the AI service;

* maintain conversation history;

* provide support;

* improve Knowledge Bases;

* identify gaps;

* troubleshoot;

* improve products; or

* fulfil another legitimate purpose.

Retention may also depend upon the functionality and retention policies of the underlying AI or software platform.

21.7 Customer-Controlled Software Data

Information stored in software accounts provisioned or managed through Scale Certified may be retained and deleted according to:

* the applicable product terms;

* relevant software terms;

* applicable Data Processing Addenda; and

* the underlying platform's technical capabilities.

Customers are responsible for preserving information they are entitled to retain before an account is closed or deleted.

21.8 Legal Holds

We may retain information for longer than our ordinary period where necessary because of:

* litigation;

* a complaint;

* an investigation;

* a payment dispute;

* tax matters;

* fraud;

* regulatory requirements; or

* another legal hold.

When information is no longer reasonably required, it may be deleted or anonymised.

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22. INFORMATION SECURITY

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

* unauthorised access;

* unauthorised disclosure;

* loss;

* misuse;

* alteration; and

* destruction.

Depending on the system involved, safeguards may include:

* password protection;

* access controls;

* role-based permissions;

* authentication;

* encryption provided through service providers;

* secure payment processors;

* restricted staff access;

* security monitoring; and

* other technical safeguards.

No internet transmission, cloud provider, software service or electronic storage system can be guaranteed to be completely secure.

Customers are responsible for maintaining the security of their own:

* passwords;

* devices;

* email accounts;

* login credentials; and

* authorised users.

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23. PERSONAL DATA BREACHES

If we become aware of a personal data breach, we will investigate and respond in accordance with applicable law.

Where required, this may include notification to:

* an appropriate regulator;

* affected individuals;

* affected customers; and/or

* other legally required parties.

Where Scale Certified is processing information on behalf of a customer, we may instead notify and assist that customer in accordance with applicable processor obligations.

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24. YOUR PRIVACY RIGHTS

Your rights depend on:

* your location;

* applicable law;

* the information involved; and

* our lawful basis for processing.

Where applicable, you may have rights including:

24.1 Access

You may have the right to request information about personal data we process about you and obtain a copy.

24.2 Correction

You may ask us to correct inaccurate information.

24.3 Deletion

You may have the right to request deletion in certain circumstances.

The right to deletion is not absolute.

We may retain information where required or permitted for purposes including:

* legal obligations;

* tax;

* accounting;

* fraud prevention;

* contractual records;

* disputes; and

* legal claims.

24.4 Restriction

You may have the right to request restriction of processing in certain circumstances.

24.5 Portability

Where applicable, you may have the right to receive certain personal information in a structured, commonly used and machine-readable format.

24.6 Objection

Where applicable, you may have the right to object to processing based on your particular circumstances.

DIRECT MARKETING

Where applicable, you may object to the use of your personal information for direct marketing at any time.

24.7 Withdrawal of Consent

Where processing is based upon consent, you may withdraw your consent.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

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25. HOW TO EXERCISE YOUR RIGHTS

To make a privacy or data-protection request, email: [email protected]

Please use a subject such as:

Privacy Request

or

Data Protection Request

where possible.

We may ask for reasonable information necessary to:

* verify your identity;

* confirm your authority;

* locate the relevant information; and

* prevent unauthorised disclosure.

If your request relates to information for which one of our customers is the controller, we may direct the request to that customer or assist them as required.

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26. UK AND EEA RIGHTS

Where UK GDPR or EU GDPR applies, individuals may have the rights described above together with any additional rights provided by applicable data protection law.

You may also have the right to complain to an applicable supervisory authority.

For individuals in the United Kingdom, the relevant regulator is the:

Information Commissioner's Office (ICO).

We encourage you to contact us first so that we have an opportunity to address your concern.

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27. CANADIAN PRIVACY RIGHTS

Where Canadian privacy law applies, individuals may have rights including rights to:

* understand how personal information is processed;

* access certain personal information;

* correct inaccurate information;

* withdraw certain consent; and

* raise a privacy complaint.

Requests may be sent to: [email protected]

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28. UNITED STATES PRIVACY RIGHTS

Residents of certain United States states may have additional rights where applicable law applies to Scale Certified's processing.

Depending on the jurisdiction, these may include rights to request:

* access;

* correction;

* deletion;

* portability;

* information about disclosures;

* opt-out of targeted advertising;

* opt-out of certain “sharing”;

* opt-out of qualifying “sales”;

* opt-out of certain profiling; and

* appeal certain privacy decisions.

Not every right applies in every state or circumstance.

As explained above, Scale Certified does not sell personal information for monetary consideration.

Certain advertising activities may nevertheless be classified as regulated sharing or targeted advertising under some laws.

Privacy requests may be sent to: [email protected]

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29. AUTOMATED DECISION-MAKING

Scale Certified uses automation and artificial intelligence in various operational and product-related contexts.

This may include:

* marketing automation;

* AI responses;

* payment fraud detection;

* workflows;

* email automation;

* account processes; and

* analytics.

As of the Effective Date, we do not ordinarily use personal information to make solely automated decisions that produce legal or similarly significant effects on individuals.

If this materially changes, we will provide appropriate information and safeguards where required by law.

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30. SPECIAL-CATEGORY AND SENSITIVE INFORMATION

Most Scale Certified products do not require highly sensitive personal information.

Unless genuinely necessary, please do not provide information relating to:

* racial or ethnic origin;

* political opinions;

* religion;

* philosophical beliefs;

* trade-union membership;

* genetics;

* biometric identification;

* health;

* sexual orientation;

* criminal convictions;

* criminal offences;

* government identification;

* account passwords;

* authentication credentials; or

* full payment-card information.

Where we intentionally process special-category or similarly protected information, we will do so only where an appropriate legal basis and any additional required condition exist.

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31. CHILDREN

Scale Certified products and business services are generally intended for adults.

We do not knowingly market our business products to children under eighteen (18).

If you believe a child has improperly provided personal information directly to Scale Certified, please contact: [email protected]

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32. THIRD-PARTY LINKS

Our websites, courses, products and communications may contain links to websites or services operated by third parties.

Scale Certified does not control the privacy practices of independent third-party websites.

When you interact with a separately controlled third-party platform, that provider's own privacy policy may apply.

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33. FUTURE PRODUCTS AND TECHNOLOGY

Scale Certified is an evolving business.

We may:

* launch new products;

* retire products;

* introduce new memberships;

* change course platforms;

* change CRM providers;

* introduce new AI tools;

* change community platforms;

* add analytics;

* introduce advertising platforms;

* introduce accounting software;

* change payment providers;

* add integrations; or

* otherwise change our technology and product infrastructure.

This Privacy Policy is intended to apply broadly to Scale Certified, but we will update it where a new activity materially changes how personal information is processed or requires additional privacy information.

Where applicable law requires consent or another specific legal condition for a new activity, this Privacy Policy alone does not replace that requirement.

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34. CHANGES TO THIS PRIVACY POLICY

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

* changes to our business;

* new products;

* changes in technology;

* changes in service providers;

* changes in data-processing activities;

* legal changes;

* regulatory guidance;

* security requirements; or

* improvements to transparency.

The current version will display its applicable effective or revision date.

Where required by law or where a change is particularly significant, we may also notify affected individuals using an appropriate communication method.

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35. RELATIONSHIP WITH PRODUCT TERMS

Individual Scale Certified products may be subject to separate:

* Terms of Use;

* Terms of Service;

* licence terms;

* software terms;

* Data Processing Addenda;

* refund policies;

* community rules; or

* supplemental privacy notices.

Those documents should be read together with this Privacy Policy where applicable.

Product-specific contractual terms govern the commercial use of that particular product, while this Privacy Policy describes Scale Certified's general handling of personal information.

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36. CONTACT US

For questions about this Privacy Policy or how Scale Certified processes personal information, contact:

6IX Media Group Limited

Trading as Scale Certified

Company Number: SC650838

Email: [email protected]

For privacy-rights requests, please use the subject:

Privacy Request

or

Data Protection Request

where appropriate.

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37. SUMMARY

By interacting with Scale Certified, you should understand that:

1. 6IX Media Group Limited operates Scale Certified and is generally the primary controller of personal information collected through our business.

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

3. We collect information necessary to operate our websites, deliver products, process payments, manage accounts, provide support and communicate with customers.

4. We use third-party providers including payment, CRM, advertising, analytics, course, communications, AI and automation platforms.

5. Personal information may be processed outside the United Kingdom subject to applicable international-transfer requirements.

6. We may use marketing and advertising technologies subject to applicable law and consent requirements.

7. You may unsubscribe from marketing email at any time.

8. Scale Certified does not sell personal information for monetary consideration.

9. Scale Certified does not use customer-controlled client or prospect databases hosted within customer software accounts for Scale Certified's own marketing.

10. Certain calls, workshops or training sessions may be recorded, transcribed and retained as educational content.

11. Certain Scale Certified services use artificial intelligence, and AI interactions may be stored and reviewed for legitimate service and improvement purposes.

12. Customers remain responsible for the lawful handling of information belonging to their own clients, customers, leads and prospects.

13. You may have privacy rights depending on your jurisdiction.

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