Privacy policy

Gravilo Limited ("'we"), based in Hong Kong, is responsible for the processing of personal data as shown in this privacy statement.

In this Privacy Statement we explain to you which personal data we collect and use, and for what purpose we do this. We recommend that you read this Privacy Statement carefully. This Privacy Statement applies to our website, www.scale-consultancy.com and related websites and Services.

This Privacy Statement was last amended on: August 19, 2025

Use of personal data

If you use the websites and related Services that we offer, you may share personal information with us. We collect and use personal data that you, or your company, share directly with us. We will not use the personal data for purposes other than those described in this statement, unless you have given permission for this in advance.

Types of data collected

When you use our Services, we may collect the following information:

• First and last name
• Address data
• telephone number
• E-mail address
• IP address
• Other personal data that you actively provide, for example by creating a profile on this website, in correspondence and by telephone
• Information about your activities on our website
• Data about your surfing behavior across different websites (for example because this company is part of an advertising network)
• Internet browser and device type
• Bank account number
• Grounds for processing

Privacy law requires us to say what "legal grounds" we have to use your data. We need information from you because of the contractual agreements between you and Scale Consultancy, such as your purchase of a product or service or your right to warranty. This is the case with:

• Handling your order
• Handling your payment
• Delivery & Returns
• Contact with our employees and customer service
• Gravilo Limited analyzes your behavior on the website in order to improve the website and to tailor the range of products and services to your preferences.
• Scale Consultancy also processes personal data if we are legally obliged to do so, such as data that we need for our tax return

In addition, we can use your data in the case of 'legitimate interest'. This means that we want to provide all our customers with the most optimal, personal service. We always think about your privacy. This is true for:

•     Reviews & customer satisfaction survey
•     Contact with our employees and customer service
•     Visit the Titan Rock Marketing website and academy website
•     Account
•     Newsletter & email
•     personal advice
•     Actions
•     social media
•     Security and WIFI

We may also have a legal obligation to use your data, for example when we suspect fraud. And sometimes you have given us permission to use your data, such as when you sign up for the newsletters, challenges, online training courses or e-books. We keep this neat.

Retention of personal data

We do not store and use your data for longer than necessary. We will then delete all data we have about you. Or do we use your data anonymously, because we need certain data for internal analyzes and reports.

Sounds simple, but how does that work in practice? We adhere to certain terms, after which we delete your data. Here they are:
We delete inactive customer accounts after 7 years. After that period, we only use your data anonymously, for internal reports.

The tax authorities require us to keep our administration with your invoice, payment and order details for 7 years. After that, we only use anonymous data for internal reports.

If you have been employed by us, the tax authorities also require us to keep the payroll administration for 7 years.

If you have registered for the newsletter or have given permission to receive personalized messages, we will keep that permission for 5 years. Even if you decide at some point that you no longer wish to receive the newsletter or personalized messages, we will retain the withdrawal of your request for 5 years. We do not store the e-mails you receive from us for longer than 60 days. After that period, we only use your data anonymously, for internal reports.

Your rights

Of course you remain in control of your data. Would you like to have free access to your personal data and receive a copy? Or do you want to change, delete, limit use or adjust your e-mail preferences? No problem. Let us know by post or email. In this way you can also object to the use of your data for marketing purposes or indicate that you believe that your privacy outweighs our interests. In that case, we will review the situation.

It's easy to unsubscribe from the newsletter. You can do this in the link at the bottom of the newsletter itself. We want to make sure that you really are you. Therefore, we may request additional information from you to establish your identity. We also do this for unclear requests.

Share with others

We will not share your information with others without your permission, unless this is necessary in the context of the execution of the agreement that you, or your organization, have concluded with us, or unless this is a legal obligation.

Transfer of personal data

In order to achieve the purposes described in this Privacy Statement, we may transfer your data outside of the EEA. If this is the case, we will take the appropriate measures to ensure that personal data is properly secured. For transfers to the United States, we will ensure that such US party complies with the Privacy Shield. For other transfers, we may transfer your data to a country recognized by the European Commission that offers an adequate level of protection with regard to Personal Data.

Analytics

Data that you provide may be stored for statistical analysis, including via Google Analytics. These statistics are used to optimize the Services. This way we can see how our visitors use the website and improve the website on that basis. Where possible, we will pseudonymise this data.

Cookies

A cookie is a small text file that is stored in the browser of your computer, tablet or smartphone when you first visit our website. Gravilo Limited uses functional, analytical and marketing cookies.

Gravilo Limited can send you targeted content by combining your data – manually or with the help of cookies. So that they better match your interests, prior knowledge and products that you have already purchased.

On your first visit to www.scale-consultancy.com you were informed about the cookies that Gravilo Limited uses and you have or have not given permission for the placing of marketing cookies. Your consent has been saved, so that you do not receive a cookie notification every time.

Cookies are generally stored for the duration of the (browser) session. In addition, your IP address may be stored in the log files of our web server when you use our Services. This is necessary to properly administer and secure our Services. We do not use your IP address to track or register your online behavior. We are usually unable to associate your IP address with your name, address or other identifying information unless you provide us with such information and continue to use the same IP address.

If you do not wish to receive cookie notifications, you can set your internet browser to store more cookies. You can also delete all previously stored information via the settings of your browser.