Privacy Policy

Effective Date: April 2, 2025

At I.M. Influence Media LTD, protecting your personal data is our priority.

Whether you use the platform ScaleUGC (the "Platform") as our client (the "Client") and as part of the management of our contractual relations with our Client, we may collect personal data about you. The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") and Cyprus Law 125(I)/2018 on the Protection of Natural Persons Regarding the Processing of Personal Data and the Free Movement of Such Data (together the "Applicable Regulations").

1. Who is the data controller?

The data controller is I.M. Influence Media LTD, with Registration number: HE429073, and whose head office is located at Etolon 1, 2221, Nicosia, Cyprus ("Us" or "We") when browsing on our Platform or when using your account on our Platform as our Client.

2. What personal data we collect?

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

Identification data (e.g. full name, email addresses);
Data relating to your professional life (e.g : company name, position/function, company size, company website, logo);
Data relating to your orders;
Login data (e.g. logs, IP address);
If you choose to sign in using a third-party authentication service (e.g., Google or Microsoft), certain data such as your name and email may be collected from that service. By choosing this method, you agree that the service may share this information with us. We do not collect your third-party account password;
Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID);
Location data;
Data related to recordings from telephone calls with our customer care service (e.g. content of the calls, dates of the calls);
Economic and financial data (e.g. bank details);
Data related to your credit cards.
Any information you wish to send us as part of your contact request.

We inform you, when collecting your personal data, whether some of these data are mandatory or optional.

3. On what legal basis, for what purposes and for how long do we keep your personal data?

Objectives	Legal basis	Data retention period
To provide you with our services available on our Platform through your account	Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract	When you have created your account: personal data are retained for the duration of your account. Your connection logs are kept for 10 weeks. If your account is inactive for a period of 2 years, it will be deleted if you do not respond to our reactivation email. In addition, personal data may be archived for probationary purposes for a period of 5 years.
To perform operations related to contracts, orders, invoices and customer relationship management	Performance of a contract to which you are party	Personal data are retained for the duration of our business relationship. In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years. The data relating to your contract and the elements relating to the signature of the contract are stored for 10 years from the conclusion of the contract / the date of delivery of the goods / the performance of the service. The data related to your credit card are retained by our payment service provider. The CVV2 (Card Verification Value), listed on your credit card details, will not be stored.
To improve our services	Our legitimate interest in improving our services	Recording of telephone calls: 6 months from the date of collection. Telephone call content analysis documents: 1 year from the date of collection. The personal data are retained for 6 months.
To manage your opinions on our products, services or content	Our legitimate interest in collecting your opinions on our products, services	2 years from the publication of the opinion
To create a database of customers and prospects	Our legitimate interest in developing and promoting our business	For our customers: their personal data are retained for the duration of our business relationship. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action).
To send newsletters, requests and direct marketing mailings	For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news. For our prospects: our legitimate interest in winning customer loyalty and informing our customers of our latest news	Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action).
Making cold calls	Our legitimate interest in developing and promoting our business	Data is kept for 3 years from the date of your last contact. We undertake to check beforehand that your number is not on a BLOCTEL-type opposition list.
To answer to your information request and other inquiries	Our legitimate interest in responding to your inquiries	Personal data is kept for a period of 3 years from the date of your last contact.
To comply with our legal and regulatory obligations	Legal and regulatory obligations	Invoices are archived for a period of 10 years. In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years. The data relating to your contract and the elements relating to the signature of the contract are stored for 10 years from the conclusion of the contract / the date of delivery of the goods / the performance of the service.
To elaborate analytics (navigation, Platform audience, etc.) and improve the functionality of the Platform by depositing audience measurement cookies	Your consent	The personal data are retained for 25 months.
To process data subjects' requests to exercise their rights	Our legitimate interest in responding to your requests and keeping records of them	If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted.

4. Who are the recipients of your personal data?

(i) The following categories of recipients will have access to your personal data:

The staff of our company;

(ii) Our processors: artificial intelligence service provider, provider of lipsync, provider of generative voice AI, hosting service provider, newsletter sending service provider, audience measurement and analysis service provider, electronic messaging service provider, secure payment service provider, invoicing tool, cookie management tool, etc.;

(iii) If applicable: public and private organisations, exclusively to comply with our legal obligations.

5. Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company AWS, located in the European Union.

As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or an approved certification mechanism; or
The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.

6. What rights can you exercise on your personal data?

You have the following rights with regard to your personal data:

Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.
Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.
Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.
Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.
Right to erasure ("right to be forgotten"): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.
Right to file a complaint to a competent supervisory authority (in France, the CNIL), under article 77 of the GDPR, if you consider that the processing of your personal data constitutes a breach of applicable regulations.
Right to define instructions related to the retention, deletion and communication of your personal data after your death.
Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

7. What cookies do we use?

For more information on cookies management, please consult our Cookies Policy.

8. Contact information for data privacy matters

Contact email: miran@scaleugc.ai

Contact address: Etolon 1, 2221, Nicosia, Cyprus

9. Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.