Privacy policy

1. Introduction

Welcome to Brandscaling. This Privacy Policy explains how Brand Scaling Ltd. (“Brandscaling,” “we,” “us,” or “our”) collects, uses, and shares information about you when you use our iOS application (the “App”) and the services provided through it. We are committed to protecting your privacy and ensuring that your personal data is handled with transparency and care.

This policy is available within the App at Settings > Privacy Policy and online at brandscaling.co.uk/privacy-policy.

For the purposes of the UK General Data Protection Regulation (UK GDPR), Brand Scaling Ltd. is the data controller.

2. Information We Collect

We collect information in a few different ways to provide and improve our services.

2.1 Information You Provide Directly

• Account Information: When you create an account, we collect your name and email address.
• E-DNA Profile Data: We collect your responses to the E-DNA (Entrepreneurial DNA) assessment questions. This information is used to generate your unique E-DNA profile.
• Workbook Data: We collect the content you create and input into your workbooks, including your goals, reflections, and answers to prompts.

2.2 Information Collected Automatically

Device and Usage Information: We collect information about your device and how you interact with our App. This includes device type, operating system, app version, crash reports, and analytics on feature usage. This data is anonymised or aggregated and is not linked to your personal account.

3. App Store Privacy Data Types — Disclosure

We are transparent about the data we collect, as outlined in our app store privacy details. The table below summarises this for your convenience.

4. How We Use Your Information

We use the information we collect for the following purposes:

• To create and manage your account.
• To generate your personalised E-DNA profile and provide you with tailored insights.
• To power the Decision Intelligence Agent features.
• To enable you to create, store, and manage your workbooks.
• To monitor and analyse usage and trends to improve the App’s performance and user experience.
• To communicate with you about your account or updates to our services.

5. Third-Party AI Processing

To provide our Decision Intelligence Agent features, we use services from trusted third-party AI providers (OpenAI, Anthropic, Google, DeepSeek). This section explicitly details the data shared with these services.

5.1 What Data Is Sent to Third Parties?

When you interact with the Decision Intelligence Agent, we send a limited, session-scoped set of your data to our AI partners to generate a relevant response. We never share your name, email, or other direct personal identifiers with these partners. The specific data transmitted is as follows:

• Your E-DNA Profile Summary: A high-level summary of your E-DNA type (e.g., “Architect, Alchemist”).
• Your Current Query: The specific question or prompt you just entered into the chat.
• Recent Conversation History: The immediate preceding turns of your conversation with the AI agent to provide context.

5.2 Who Receives This Data?

Your data may be sent to one or more of the following trusted service providers, depending on the AI model you select within the App, for the sole purpose of delivering the AI Agent service:

• OpenAI, L.L.C. (San Francisco, USA)
• Anthropic, PBC (San Francisco, USA)
• Google, LLC (for Gemini) (Mountain View, USA)
• DeepSeek, Ltd. (Hangzhou, China)

5.3 Your Permission — Explicit Consent Before Data Is Shared

In compliance with platform guidelines, we will not transmit any of your data to a third-party AI service without your explicit permission. This applies to both registered and guest users.

Before you can use the AI agent’s features for the first time, the App will present a clear, one-time consent screen. This screen will:

1. State that the feature uses third-party AI services to function.
2. Clearly list the specific data that will be shared (as detailed in Section 5.1).
3. Name the third parties who may receive the data (OpenAI, Anthropic, Google, DeepSeek).
4. Require you to actively tap a button to provide your consent before proceeding.

If you do not consent, the rest of the App remains fully functional, but the AI agent’s features will be disabled.

5.4 Withdrawing Consent

If you have previously granted consent and wish to withdraw it, you can do so at any time. Navigate to Settings > Privacy > AI Agent Data and select “Withdraw Consent.” This will immediately disable all AI agent data transmission and deactivate the AI agent features until consent is re-granted.

5.5 Equal Protection Commitment

All our third-party AI service providers are contractually bound by Data Processing Agreements (DPAs). These agreements ensure they provide the same or equal protection of your data as stated in this Privacy Policy. They may not use data transmitted from the Brandscaling App for their own advertising, marketing, or to train their models. All international data transfers are governed by Standard Contractual Clauses approved under UK GDPR.

6. Other Data Sharing

We do not sell your personal data. We may share limited data with other trusted service providers strictly for the purposes stated:

7. Guest Users and Data Collection

If you use features of the App that are available without creating an account (such as the guest-accessible AI chat), we will not collect any personal data from you. As noted in Section 5.3, we will still ask for your explicit consent before transmitting any chat data to our third-party AI partners. Any interaction with the AI Agent in a guest mode will be processed anonymously and will not be linked to any device or user identifier.

8. Future Features (Phase 2)

Brandscaling is an evolving ecosystem. Future versions of the App may include additional features that require new data processing, such as:

• Social Logins (Apple, Google): To provide alternative ways to create an account.
• Team Collaboration Features: To allow you to share insights or workbooks with team members within the App.
• Advanced AI Capabilities: Including features that may process additional data types (such as workbook content) to provide deeper, more personalised insights. For example, we may use a vector database (e.g., from Pinecone Systems, Inc.) to allow the AI to find relevant information from your past work without sending the raw text for every query.

Before any such features are enabled, this Privacy Policy will be updated, and we will obtain your explicit consent for any new data sharing where required.

9. Legal Bases for Processing (UK GDPR)

We process personal data only where a valid legal basis applies:

• Performance of a Contract: To provide account access, E-DNA profile generation, and workbook functionality.
• Legitimate Interests: To monitor app performance, ensure security, and improve services.
• Consent: For all AI agent data processing involving transmission to third parties.

10. Data Storage, Retention, and Deletion

We retain your personal data for as long as your account remains active. If you delete your account, your personal data will be permanently deleted within 30 days, except where retention is required for legal or accounting purposes.

In-App Account Deletion: You can permanently delete your Brandscaling account and all associated personal data directly from within the App at any time. To do so, navigate to Settings > Account > Delete Account. You will be asked to confirm your decision before deletion is initiated. This action is irreversible.

You can also request deletion from the web at brandscaling.co.uk/delete-account.

11. Your Rights (UK GDPR)

You have the right to access, correct, or request deletion of your personal data. You may also restrict or object to certain processing and request a copy of your data. To exercise these rights, please contact us.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk if you believe your data protection rights have been violated.

12. Security

We implement appropriate technical and organisational safeguards, including encryption in transit (TLS) and at rest (AES-256), access controls, and regular monitoring for unauthorised access.

13. Tracking Technologies and App Tracking Transparency

The Brandscaling App does not use cookies or similar technologies to track users across third-party apps or websites for advertising purposes. As a result, the App does not present an App Tracking Transparency (ATT) permission prompt.

14. Children’s Privacy

The Brandscaling App is intended exclusively for individuals aged 18 and over. We do not knowingly collect personal data from children.

15. In-App Purchases

The Brandscaling App may offer optional in-app purchases that allow you to buy digital services, features, or content available within the App. These purchases may be presented to you based on your personalised tags, tiers, or other profile characteristics within the Brandscaling ecosystem.

All in-app purchases are processed securely through the relevant app store payment system. Brand Scaling Ltd. does not collect or store your payment card details.

The digital services and content available through in-app purchases are the intellectual property of Brand Scaling Ltd. and are licensed, not sold, to you for use within the App in accordance with our terms of service.

16. No Refund Policy

All in-app purchases are final and non-refundable except as required by applicable law. If you believe you are entitled to a refund, please contact the platform you purchased from.

17. Purchase Restoration

If you have previously purchased the Full E-DNA Report, you can restore your purchase at no additional cost by tapping ‘Restore Purchases’ in the app settings. Restoration requires you to be signed in with the same store account used for the original purchase.

18. Updates to This Policy

We may update this Privacy Policy as the App evolves or as legal requirements change. Material changes will be communicated in-app or via email before they take effect. The “Updated” date at the top of this document reflects the date of the most recent revision.

19. Contact Us

For privacy questions, data protection requests, or to exercise your rights, please contact:

Brand Scaling Ltd.
35 Wycome Road, Birmingham, UK

Email: support@brandscaling.co.uk

Website: brandscaling.co.uk/contact