Privacy notice.

The Scalable Creative is operated by Thomas Gamblin, based in the United Kingdom. For all privacy enquiries, contact privacy@thescalablecreative.com.

Depending on how you interact with us, we may collect the following categories of personal data:

• Identity and contact data. Name, email address, business name, country, and the answers you give in our application form.
• Diagnostic data. The answers you provide in the Snapshot diagnostic, and the resulting score.
• Payment data. Limited information from our payment provider (last four digits, billing country, transaction reference). We do not store full card numbers.
• Account and usage data. Information about your use of the Programme, the Tools, and the community space, such as logins, lesson progress, and posts.
• Communications data. Emails and messages you send to us, and our responses.
• Technical data. IP address, browser type, device type, and similar data collected through analytics and security tooling.

We do not knowingly collect special category data. Please do not share special category information through the Programme or the community space unless we have asked you to.

We use a small number of trusted processors to operate the Programme. Each processor only receives the data needed to perform its function and is bound by a data processing agreement.

• Stripe. Payment processing.
• GoHighLevel. CRM, email delivery, and application handling.
• Circle. Community space hosting.
• Make.com. Workflow automation between the above.
• Google Workspace. Internal email and document storage.
• ScoreApp. Hosting of the Snapshot diagnostic.
• Analytics and error monitoring tools, where used.

We do not sell personal data. Where we instruct a processor to act on our behalf, we remain the data controller.

Some of our processors are based outside the United Kingdom. Where data is transferred internationally, we rely on UK-approved transfer mechanisms, including the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or transfers to a country recognised as providing an adequate level of protection.

We keep personal data only for as long as needed for the purpose for which it was collected, plus any period required to meet our legal and tax obligations. As a guide:

• Application data not converted into a membership: up to twelve months.
• Member account data: for the duration of the membership and for six years after the membership ends, to comply with tax and contract record requirements.
• Marketing data: until you withdraw consent or unsubscribe.
• Snapshot results: up to twenty-four months, unless you ask us to delete them sooner.

Under UK data protection law, you have the right to:

• Access the personal data we hold about you.
• Have inaccurate data corrected.
• Ask us to erase your data, in the circumstances permitted by law.
• Restrict how we process your data.
• Receive your data in a portable format, where applicable.
• Object to processing carried out on the basis of legitimate interests, including direct marketing.
• Withdraw your consent at any time, without affecting the lawfulness of any processing carried out before withdrawal.

To exercise any of these rights, email privacy@thescalablecreative.com. We respond within one calendar month.

We use a small number of cookies that are essential for the website to function, plus optional cookies for analytics and to remember interface preferences such as dark mode. You can refuse non-essential cookies through your browser, and we will provide a clear consent control where required.

The Programme is intended for business owners and is not aimed at anyone under the age of eighteen. We do not knowingly collect personal data from children.

We may update this notice from time to time. The current version will always be available at this URL. Material changes will be highlighted, and where appropriate, we will notify members by email.

If you have any concern about how we handle your data, please contact us first at privacy@thescalablecreative.com. You also have the right to complain to the Information Commissioner’s Office (ICO) in the United Kingdom at ico.org.uk.