Privacy Policy

This Privacy Policy explains how BRASK INC. (“Company,” “We,” “Us,” or “Our”) collects, uses, shares, and otherwise processes your personal data and your rights regarding your personal data.

We provide you with our website https://www.scale-ads.com/ as well as the services and offerings made available to you through this website (“Services”). When you use the Service or interact with us in any way (for example, by communicating via email), you may provide us with your personal data. This Privacy Policy explains how we handle and protect your personal data.

This Privacy Policy applies to your use of the Service. By using the Service, you acknowledge that you have read this Privacy Policy. This Policy explains our privacy practices and does not create contractual rights or obligations beyond those provided by law.

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions will have the same meaning regardless of whether they appear in singular or in plural.

Who We Are & How to Reach Us
Controller. BRASK INC., 8 The Green, STE A, Dover, DE 19901, is the controller for the processing described in this Privacy Policy.
Privacy Contact. Email: legal@brask.ai
(or by mail to the address above, Attn: Privacy).

For the purposes of this Privacy Policy:

• “Account” means a unique account created for You to access our Service or parts of our Service.
  

• “Device” means any device that can access the Service such as a computer, a cell phone, or a digital tablet.
  

• “Personal Data” means any information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked, directly or indirectly, with an individual or household (e.g., identifiers such as name, email, IP address or device ID; account data; user content; usage and log data; approximate location data; inferences drawn from other data). “Personal Data” does not include de-identified, aggregated, or anonymized information.
  

• “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  

• “You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  

Information You Provide to Us

When you use or access the Service, create an Account, send a message to us, or participate in activities on the Service, you may input personal data into the Service.

We collect the following categories of data that you voluntarily provide to us:

• Information that you enter, post, send, or submit to our Service (full name, email, photos and videos, account settings, or information contained in the communications that you send to us by email, mail, or in any other form).
  

Information Collected from Third Parties

We may receive information about you from other users, third-party services, public social media platforms, or public databases. For example, social media platforms may display your mailing address, email, or phone number.

Information Collected Automatically

Certain information is collected automatically when you use or visit our Service. This information does not reveal your identity (such as your name or contact information), but may include information about your device, its use, and other technical information. This information helps us maintain security, ensure optimization of the Service for your needs, and facilitate customer support.

We use cookies, pixels, local storage, and SDKs to operate the Service, remember preferences, measure performance, and improve our features. In regions where consent is required (e.g., EEA/UK), we set non-essential cookies/SDKs only after you consent via our banner. You can adjust your cookie settings in your browser and device controls.

The tracking technologies automatically collect the following categories of data:

• Browser data: information that your browser automatically sends when you use the Service, including IP address, browser type, browser language, settings, and Service usage patterns.
  

• Device data: device type and model, operating system and version, unique device identifiers, preferred language, approximate location (derived from IP), and settings.
  

• Usage data: information about your use of the Service, including patterns, time, and date of your use of the Service.
  

• Analytics data: general information about traffic and usage trends for the Service.
  

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
  

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  

• To contact You: To contact You by email, via Service, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  

• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  

• To manage Your requests: To attend and manage Your requests to Us.
  

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
  

We use analytics to understand usage trends and improve the Service. We do not allow third parties to collect Personal Data for their own marketing or targeted advertising on our Service.
‍
We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, or to contact You.
  

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.
  

• With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
  

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  

• With Your consent: We may disclose Personal Data for other purposes only with Your consent.
  

Where the GDPR/UK GDPR applies, we process Personal Data on these legal bases:

• Provide the Services, account, and support — performance of a contract (Art. 6(1)(b)).
  

• Security, fraud prevention, integrity of the Service — legitimate interests (Art. 6(1)(f)).
  

• Analytics and product improvement — legitimate interests (Art. 6(1)(f)); where required, consent (Art. 6(1)(a)).
  

• Marketing communications — consent (Art. 6(1)(a)) or legitimate interests (Art. 6(1)(f)), with the right to object at any time.
  

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit), for internal analysis purposes. This data is generally retained for a shorter period of time, except when it is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

International Data Transfers

We operate globally and may transfer Personal Data to countries other than your country of residence. When we transfer Personal Data internationally, we use Standard Contractual Clauses (SCCs) approved by the European Commission (and the UK International Data Transfer Addendum, where applicable).

Our Subsidiaries and business transactions

We may share Your Personal Data with Our subsidiaries, affiliates, and co-owners. We may also disclose personal data to operators of the Service, subsequent owners, and their advisors in connection with a merger, reorganization, sale of our assets, or other change of control. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Service providers

We may share Your Personal Data with service providers when they need access to your personal data to perform services for us, such as monitoring and analyzing Service, web hosting, debugging services, payment processing, email and productivity services, survey providers, and customer service providers.

Analytics Providers
‍
We share limited information with analytics vendors strictly as our service providers acting on our behalf and under our instructions. They are not permitted to use Personal Data for their own marketing or targeted advertising.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
  

• Protect and defend the rights or property of the Company
  

• Prevent or investigate possible wrongdoing in connection with the Service
  

• Protect the personal safety of users of the Service or the public
  

• Protect against legal liability
  

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies. We advise you to review their Privacy Policy separately.

Disclosure of Anonymous Information

We may disclose anonymous information to any third party without notification. Anonymous information means information which does not allow the identification of an individual user, such as aggregated, anonymized, or de-identified information about the use of our services. Such information does not constitute personal data.

When you use our website and we decide why and how to process Personal Data, we act as a controller. When we provide services to business customers and process Personal Data on their instructions, we act as a processor under a Data Processing Addendum (DPA).

We implement appropriate administrative, technical, and physical safeguards designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include access controls, encryption in transit, and other security practices appropriate to the nature of the data and our processing. However, no security measures are perfect or impenetrable.

You have the following rights to your personal data:

• The right to know what data we have about you. To exercise this right, please contact us at legal@brask.ai.
  

• The right to correct, delete, or update your personal data. You can access and modify your personal data through your account or the settings section of the Service. If you need assistance, please contact us at legal@brask.ai. Please note that sometimes we may not be able to modify or delete certain information. For example, we are required by law to keep certain information for a defined period.
  

• The right to opt out of receiving electronic marketing communications from us. We may periodically send you emails and messages promoting the use of the Service. You can opt out (unsubscribe) of receiving these messages by following the instructions included in each email or message. If you have any additional questions, please contact us at legal@brask.ai.
  

Depending on your U.S. state, you may have rights to access, correct, delete, and obtain a portable copy of your Personal Data. To exercise these rights, contact us at legal@brask.ai
with the subject “Privacy Request.” We will verify your identity using information we already hold.
We do not sell or share Personal Data as those terms are defined by applicable U.S. privacy laws, and we do not engage in targeted advertising. If this changes, we will update this Policy and provide you with a method to opt out.
Where permitted by law, you may use an authorized agent to submit a request. We may require proof of authorization and verification of your identity.
If we deny your request, you may appeal by emailing legal@brask.ai with the subject “Privacy Appeal.” We will respond within the timeframe required by law and inform you how to contact your state regulator if you disagree.

For how to exercise your rights under California law, please see U.S. State Privacy Rights above. We do not sell or share Personal Data.
If you are a California resident, you have specific rights to your personal data:

• You can request that we delete any of your personal data we have collected. But we may not be required to comply with your request if it is necessary for us to maintain your personal information for the reasons provided under California Civil Code Section 1798.105(d).
  

• You have the right to request in writing a list of:
  a. the categories of personal data we have collected in the preceding 12 months;
  b. the categories of sources from which your personal data is collected;
  c. the business or commercial purpose for collecting your personal data;
  d. the categories of third parties with whom we shared your personal data in the preceding 12 months; and
  e. the specific pieces of personal data we have collected about you during the preceding 12 months.
  

• You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know what data we have about you or the right to delete your personal data.
  

If you have any questions, please contact us at legal@brask.ai. Only you may make a verifiable consumer request related to your personal data. To verify your identity, we may ask you to verify the personal data we already have on file for you. We may ask you to provide your name, email address, and certain other pieces of identifying information.

We do not use or disclose sensitive personal information for purposes requiring a right to limit under California law. We do not sell your personal information to facilitate or enable third parties to advertise to you. We do not sell the personal data of minors under 16 years of age.

Under applicable EU regulation, you have the following rights in respect of your personal information:

• to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
  

• to rectify inaccurate personal information;
  

• to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;
  

• to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
  

• to object to decisions which are based solely on automated processing or profiling;
  

• where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
  

• to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.
  

• In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.
  

• We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.
  

Children’s Privacy

Our Service is intended for individuals 18 years and older. We do not knowingly collect Personal Data from anyone under 18; if we learn that an account belongs to someone under 18, we will delete the account and associated data. Where required by law (e.g., California), we do not sell or share the Personal Data of individuals under 16 without the required opt-in consent (parental consent if under 13).

Automated decision-making

We do not use Personal Data to make decisions based solely on automated processing that produce legal or similarly significant effects about you.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy on this page and, where required by law, by providing additional notice (e.g., via the Service or by email). The “Effective Date” at the top indicates when this Policy was last updated.

Contact Us

If you have any questions about this Privacy Policy, You can contact by sending us an email at legal@brask.ai.