Privacy Policy

Scale Theorem Pty Ltd (ABN 22 701 342 350) of Unit 2, 13 Landmann Street, Warrnambool VIC 3280, Australia ("Scale Theorem", "we", "us") is committed to protecting personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Because we serve clients internationally — including in Singapore, the United States, the United Kingdom and the European Union — this policy also describes how we handle personal data under the EU General Data Protection Regulation and UK GDPR where they apply. For personal data we hold about our clients and website visitors, we act as the data controller.

1. What we collect

• Contact and business details you provide: name, email address, phone number, company, role, country and time zone.
• Engagement information: information you share while we scope and deliver services — business performance data, documents, plans and other materials you choose to disclose.
• Session recordings and transcripts: delivery sessions, workshops and calls may be recorded (with participants informed) to produce the documented outputs that form part of our deliverables.
• Payment information: processed by our third-party payment providers. We receive confirmation of payment and limited billing details; we do not store full card numbers.
• Website and communications data: pages visited, referral source, device and approximate location collected via cookies and analytics tools, and email engagement data (such as opens) where you receive our communications.

2. How we collect it

We collect personal information directly from you (by email, phone, forms, calls and during engagements), from your organisation when it engages us, from publicly available professional sources (such as your company website or LinkedIn) where reasonable for business outreach, and automatically through our website tools.

3. Why we use it — and our lawful bases

• To deliver services and manage engagements (lawful basis where GDPR applies: performance of a contract, or our legitimate interests where we contract with your employer).
• To respond to enquiries and administer scheduling, invoicing and records (contract; legitimate interests; legal obligation for tax and accounting records).
• To send service communications about your engagement (contract; legitimate interests).
• To send marketing communications you have opted into or that we may lawfully send to business contacts — every message includes an unsubscribe option (consent; legitimate interests for business contacts).
• To operate, measure and improve our website and offerings, including analytics and, where used, advertising measurement (legitimate interests; consent where required for cookies).
• To comply with law, including tax, accounting, anti-money-laundering and sanctions obligations (legal obligation).

4. Who we share it with

We share personal information only with service providers who help us operate, under contracts that protect it: payment processors, banking and invoicing platforms, cloud document and file storage, email and productivity suites, CRM and scheduling tools, call-recording and transcription services, AI-assisted analysis tools used in delivery, analytics providers, and our professional advisers (such as our accountant) where necessary. We may disclose information where required by law or to protect our legal rights. We do not sell personal information.

5. International transfers

We are based in Australia, and our service providers may store or process data in other countries, including the United States, the European Union, the United Kingdom and Singapore. Where we transfer personal data internationally, we take reasonable steps to ensure it receives protection comparable to this policy — including using providers subject to recognised safeguards (such as adequacy decisions, standard contractual clauses, or the EU–US / UK–US data privacy frameworks) and limiting transfers to what the engagement requires.

6. Cookies and analytics

We use cookies and similar technologies for site functionality, analytics and — if we run advertising — campaign measurement. You can control or delete cookies through your browser settings; where the law of your region requires it, non-essential cookies are used only with your consent. Blocking cookies may affect parts of the site.

7. Marketing choices

You can opt out of marketing at any time using the unsubscribe link in any message or by emailing us. We will still send non-marketing communications needed to deliver an engagement.

8. Security

We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure — including access controls, reputable cloud providers, multi-factor authentication and least-privilege access to client materials. No internet transmission is completely secure; please contact us immediately if you suspect any issue.

9. Retention

We retain personal information only as long as needed for the purposes above: engagement records for the duration of the client relationship and for up to 7 years afterwards (Australian tax, accounting and limitation requirements), and enquiry or marketing data until you opt out or it is no longer needed. We then delete or de-identify it.

10. Your rights

Wherever you are, you may request access to or correction of your personal information. If the GDPR or UK GDPR applies to you, you also have the rights to erasure, restriction of processing, data portability, and to object to processing based on legitimate interests or used for direct marketing; where processing is based on consent you may withdraw consent at any time without affecting prior processing. To exercise any right, email tommy@scaletheorem.com. We will verify your identity, respond within a reasonable period (and within any period required by law — generally 30 days), and will not charge a fee except as permitted by law.

11. Complaints

If you have a privacy concern or complaint, contact us first and we will respond within a reasonable period. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (oaic.gov.au). If you are in the UK you may complain to the Information Commissioner's Office (ico.org.uk); if you are in the EU/EEA, to your local supervisory authority; and if you are in Singapore, to the Personal Data Protection Commission (pdpc.gov.sg).

12. Third-party sites

Our website may link to third-party sites and embedded content (for example, hosted video). Those services have their own privacy practices, which we do not control.

13. Changes to this policy

We may update this policy from time to time. The version published on this page, with its "last updated" date, is the current policy.

14. Contact

Privacy Officer — Scale Theorem Pty Ltd
Unit 2, 13 Landmann Street, Warrnambool VIC 3280, Australia
Email: tommy@scaletheorem.com · Phone: +61 400 067 394