Privacy Policy

1. Introduction

E.M. Social Scaling ("we", "us", "our") is committed to protecting your personal data and respecting your privacy in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and applicable national data protection legislation.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you interact with our website, purchase our services, or communicate with us.

2. Data Controller

E.M. Social Scaling is the data controller responsible for your personal data. For any privacy-related queries, contact us at: Telegram @KohinqW

3. What Data We Collect

3.1 Data You Provide Directly

Full name and contact details (email address, Telegram handle, phone number where provided).

Payment information (processed securely via third-party payment processors; we do not store card details).

Business information you share during onboarding or coaching sessions (e.g. agency name, revenue, goals).

Communications you send to us via email, Telegram, or any other channel.

3.2 Data Collected Automatically

When you visit our website, we may automatically collect: IP address, browser type and version, pages visited, time and date of visit, referring URL. This data is collected via cookies and similar tracking technologies (see Section 8).

4. Legal Basis for Processing

We process your personal data on the following legal bases under GDPR Article 6:

Contractual necessity (Art. 6(1)(b)): Processing is necessary to perform the services you have purchased or to take steps at your request prior to entering a contract.

Legitimate interests (Art. 6(1)(f)): To improve our services, communicate program updates, and protect against fraud.

Consent (Art. 6(1)(a)): Where you have opted in to receive marketing communications.

Legal obligation (Art. 6(1)(c)): Where processing is required to comply with applicable law.

5. How We Use Your Data

To deliver purchased coaching or mentorship services.

To process payments and manage your account.

To communicate with you regarding your programme, support requests, or updates.

To send marketing communications, where you have provided consent (you may opt out at any time).

To comply with legal obligations and resolve disputes.

To analyse website usage and improve our services.

6. Data Sharing & Third Parties

We do not sell your personal data to third parties. We may share your data with:

Payment processors (e.g. Stripe, PayPal) — solely to complete transactions.

Hosting and technology providers — to maintain and operate our website and systems.

Legal authorities — where required by law or to protect our legal rights.

All third-party processors are required to handle your data in compliance with GDPR.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Coaching session notes and business data are retained for the duration of your programme plus 2 years. Financial transaction records are retained for up to 7 years in compliance with tax obligations.

8. Cookies

Our website uses cookies to enhance user experience and analyse traffic. Cookies used may include: strictly necessary cookies (required for the website to function), analytics cookies (to understand how visitors use the site), and marketing cookies (to deliver relevant content), where consent is obtained.

You can manage or withdraw your cookie consent at any time via your browser settings or the cookie banner on our website. Withdrawing consent does not affect the lawfulness of processing carried out prior to withdrawal.

9. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

Right of Access (Art. 15): You may request a copy of the personal data we hold about you.

Right to Rectification (Art. 16): You may request correction of inaccurate data.

Right to Erasure (Art. 17): You may request deletion of your data, subject to legal obligations.

Right to Restriction of Processing (Art. 18): You may request that we limit how we use your data.

Right to Data Portability (Art. 20): You may request your data in a structured, machine-readable format.

Right to Object (Art. 21): You may object to processing based on legitimate interests or for direct marketing.

Right to Withdraw Consent: Where processing is based on consent, you may withdraw at any time without affecting prior lawful processing.

To exercise any of these rights, contact us via Telegram: @KohinqW. We will respond within 30 days as required by GDPR.

10. International Transfers

If your data is transferred outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or equivalent mechanisms, in accordance with GDPR Chapter V.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. However, no method of transmission over the internet is 100% secure. We encourage you to protect your login credentials and contact us immediately if you suspect any unauthorised access to your data.

12. Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your national data protection supervisory authority. For EU residents, this may be the authority in your country of residence or the country where the alleged violation occurred.

13. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any significant changes will be communicated via our website or directly to registered clients. The date at the top of this document indicates when it was last revised.

14. Contact Us

For any questions, concerns, or requests related to this Privacy Policy, please contact:

E.M. Social Scaling

Telegram: @KohinqW

Calendly: calendly.com/kohinq/btz-consulting