Privacy Policy – Scale by Rakhnianskii
Version: 1.0.0
Last updated: March 27, 2025
Application ID: 1735457580473494

Overview

SCALE is a turnkey business scaling system that fights for every client, turning every dollar of advertising budget into profit.

Our platform integrates with the WhatsApp Business API to provide a complete solution for business automation and growth.

Roles in Data Processing

It is important to understand the following roles:

• RAKHNIANSKII LTD: We are the data processor providing the technical infrastructure.
• You (our Client): You are the data controller for all your end users’ data.
• End users: Individuals interacting with your system via WhatsApp.

As the data controller, YOU bear sole and full responsibility for:

• Ensuring lawful grounds for processing your end users’ data
• Obtaining necessary consents from end users
• Providing appropriate privacy notices
• Responding to data subject requests
• Complying with all applicable data protection laws

Data We Collect and Process

1. Client Account Data

• Business contact information
• Facebook Business Manager account details
• Access credentials
• Payment information (if applicable)

2. Technical Data from WhatsApp/Meta Integration

• WhatsApp Message ID and message identifiers
• Message statuses (sent, delivered, read)
• WhatsApp users’ phone numbers and profile names
• Message types (text, image, video, location, contact)
• Timestamps of message receipt
• Template statuses (approved, rejected, suspended)
• Campaign information and sending statistics
• Account events (WABA status, policy violations, restrictions)
• Referral data (ad URL, source type, ad ID)
• Technical connection metadata (app name, API version)
• Conversation pricing information (marketing/authentication/utility/service)
• Product and catalog information
• Address data (city, postal code, street)

3. End User Data Processed on Your Behalf

• WhatsApp phone numbers and sender information
• Message content and correspondence data
• UTM parameters and attribution data (source, medium, campaign)
• Device information
• Session and user action data
• Ad click data
• Conversion data

Purposes of Data Processing

We process data exclusively for the following purposes:

• Ensuring the functionality of the WhatsApp Business API integration
• Delivering messages and notifications via WhatsApp
• Analyzing the effectiveness of templates and campaigns
• Complying with Meta/Facebook and WhatsApp requirements
• Providing usage analytics
• Administering your account
• Processing transactions (if applicable)
• Sending service messages
• Improving our services
• Ensuring technical security

Data Retention Periods

• Technical metadata is stored for the entire duration of service use and 30 days after termination
• Message history is stored in accordance with Meta’s policies, typically for no longer than 24 months.
• Client account data: service duration + 30 days
• Technical logs: 90 days
• Analytical data: 12 months
• Backups: 30 days

We may retain anonymized or aggregated data indefinitely.

Data Transfer to Third Parties

• Data is transferred to Meta/Facebook and WhatsApp as part of the necessary integration
• We do not transfer your data to other third parties, except as required by law

Specific Data Transferred to Meta/Facebook and WhatsApp

When using our service, the following categories of data are transferred to Meta/Facebook and WhatsApp to ensure the integration works:

• End users’ phone numbers and identifiers
• Message statuses and delivery data
• Message content for template verification and policy compliance
• Template metadata for review and approval
• Conversion and interaction data for required reporting

International Data Transfers

Since our service integrates with Meta/Facebook and WhatsApp, your data and your end users’ data may be transferred to and processed in countries outside the European Economic Area (EEA) or your country of residence.

To ensure an adequate level of protection for such international data transfers, we implement the following measures:

• Entering into Standard Contractual Clauses (SCCs) approved by the European Commission with data recipients
• Conducting Data Protection Impact Assessments to evaluate the recipient countries’ laws
• Implementing additional technical safeguards, such as encryption during transmission and storage

By using our service, you consent to such international data transfers in accordance with the described safeguards.

Use of Cookies and Similar Technologies

Our service may use cookies and similar technologies to ensure functionality, analyze usage, and improve user experience. This includes:

• Essential cookies: necessary for the service to work and cannot be disabled
• Analytical cookies: help us understand how users interact with the service
• Functional cookies: remember user preferences to enhance the experience

You can manage cookie settings through your browser. However, disabling certain cookies may affect the service’s functionality.

If you integrate our service into your web resources, you are responsible for obtaining the necessary consents for cookie use from your end users in accordance with applicable law.

Security Measures

We implement appropriate technical and organizational measures to protect data, including:

• Encryption during transmission and storage
• Access control and authentication
• Regular security assessments
• Staff training

Compliance with Data Protection Laws

We strive to comply with applicable data protection laws, including:

• General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA)

You are fully responsible for obtaining necessary consents from your end users for the processing of their personal data in accordance with GDPR, CCPA, and other applicable data protection laws.

Data Subject Rights

Individuals whose data is processed may have the following rights under applicable law:

• Right to access their data
• Right to correct inaccurate data
• Right to delete data
• Right to restrict processing
• Right to data portability
• Right to object to processing

To exercise these rights, end users should contact you directly as the data controller. We will assist you in fulfilling these requests.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted with a revised “Last updated” date.

Applicable Law

This Privacy Policy is governed by the laws of England and Wales

 

Company Details

• Legal name: RAKHNIANSKII LTD, 16372941
• Address: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ
• Registered in UNITED KINGDOM
• Email: support@rakhnianskii.com
• Website: https://rakhnianskii.com
• Phone: +44 (0) 7938 836206

SCALE integrates with WhatsApp Business API through an authorized Meta Business Solution Provider. SCALE itself is not an official partner of Meta Platforms Inc. or WhatsApp LLC. All mentions of integrations are for technical description purposes.