Privacy Policy

Last updated: May 7, 2026

At Skala (“we”, “us”, “our”), a product of AFFLUENT DIGITAL L.L.C-FZ, a Free Zone limited liability company registered in the United Arab Emirates, we take your privacy seriously. This Privacy Policy explains what personal data we collect when you visit our website (skala.so), book a strategy call, or engage us for our services, how we use it, who we share it with, and the rights you have over it.

This Policy is designed to comply with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”) and its implementing regulations. Where you are located in the European Economic Area or the United Kingdom, we also align our practices with the EU General Data Protection Regulation (“GDPR”) and the UK GDPR.

1. Who is the Data Controller

The data controller for personal data collected through this website and our sales process is AFFLUENT DIGITAL L.L.C-FZ, the company that operates the Skala brand and services (referred to in this Policy as “Skala”). Where we process prospect or client data on behalf of a customer to operate outbound campaigns under a service agreement, we act as a processor on behalf of that customer (the controller). For any privacy question or to exercise your rights, contact us at hello@skala.so.

2. Personal Data We Collect

  • Information you give us when you contact us, book a call, or become a client: full name, business email, phone number, company name, role, country, the message you send us, and any information you share during a sales call or onboarding.
  • Booking data generated when you schedule a call via our scheduling provider (Cal.com), including the meeting time, time zone, and any details you provide.
  • Technical data automatically collected when you visit the site: IP address, device and browser type, operating system, referring URL, pages viewed, time spent, and approximate location derived from your IP. This information may be anonymized or aggregated.
  • Cookies and consent data as described in our Cookie Policy, including your cookie preference stored in your browser.
  • Customer-account data: contract, billing, and communication records when you become a client.

We do not knowingly collect special categories of personal data (such as health, religion, biometrics) and we do not knowingly collect data from children under 18.

3. How We Use Personal Data and Lawful Bases

We process personal data for the following purposes and on the following lawful bases:

  • To respond to your enquiry and schedule meetings — performance of pre-contractual steps at your request and our legitimate interest in handling business enquiries.
  • To provide and operate the services for our clients (including managed sender infrastructure, list building, and campaign sending) — performance of the contract with the client.
  • To send service emails, contracts, invoices, and account notifications — performance of the contract and legal obligation.
  • To send occasional marketing emails about Skala (only to existing or prospective clients within applicable rules) — our legitimate interest, with the right to opt out at any time.
  • To improve the website and the services, including basic analytics — our legitimate interest in running and improving our business.
  • To comply with legal obligations (tax, accounting, anti-money-laundering, response to lawful authority requests) — legal obligation.
  • To prevent abuse, fraud, and security incidents on our infrastructure — our legitimate interest in protecting our systems and users.

4. Sharing of Personal Data

We do not sell personal data. We share personal data only with the following categories of recipients and only to the extent necessary:

  • Service providers (sub-processors) who help us run the business, such as cloud hosting, email service providers, scheduling tools (e.g. Cal.com), CRM, accounting, and analytics. They are contractually required to process the data only on our instructions and to protect it.
  • Professional advisors (lawyers, auditors, accountants) bound by confidentiality.
  • Authorities and courts, when we are legally required to do so or to protect our rights.
  • Acquirers in the event of a corporate transaction (merger, acquisition, sale of assets), subject to appropriate confidentiality obligations.

5. International Data Transfers

Skala operates from the United Arab Emirates. Some of our service providers are located outside the UAE (including the European Union, the United Kingdom, and the United States). When we transfer personal data outside the UAE, we rely on transfer mechanisms permitted by the PDPL, including contractual safeguards with the recipient and, where relevant, the recipient’s adherence to internationally recognized data protection frameworks. Where data is transferred from the EEA or the UK, we rely on the European Commission’s Standard Contractual Clauses or another lawful transfer mechanism.

6. Data Retention

We keep personal data only for as long as needed for the purposes described in this Policy:

  • Sales enquiries and prospect calls: up to 24 months from the last interaction, unless you become a client.
  • Client and contract data: for the duration of the engagement and up to 7 years after termination, in line with UAE accounting and tax obligations.
  • Website analytics: aggregated or anonymized after 14 months.
  • Marketing contacts: until you unsubscribe or object to processing.

7. Your Rights

Subject to the PDPL and, where applicable, the GDPR / UK GDPR, you have the right to:

  • Access the personal data we hold about you and obtain a copy.
  • Request rectification of inaccurate or incomplete data.
  • Request erasure (“right to be forgotten”) where conditions are met.
  • Restrict or object to certain processing, including direct marketing.
  • Request portability of data you have provided to us.
  • Withdraw consent at any time where we relied on your consent (without affecting the lawfulness of processing before withdrawal).
  • Lodge a complaint with the competent supervisory authority in the UAE (the UAE Data Office) or, if you are in the EEA / UK, your local data protection authority.

To exercise any of these rights, write to us at hello@skala.so. We may need to verify your identity before responding. We will respond within the timelines required by applicable law.

8. How We Protect Your Data

We apply appropriate technical and organizational measures, including access controls, encryption in transit, principle of least privilege, vendor due diligence, and regular review of our security posture. No system is 100% secure. If we become aware of a personal data breach affecting your data, we will notify the competent authority and, where required, you, in accordance with applicable law.

9. Outbound Email Recipients

If you received a cold email sent through Skala’s infrastructure on behalf of one of our clients, the client (not Skala) is the controller of your data. You can unsubscribe at any time by replying to the email or using the opt-out link. You may also write to us at hello@skala.so and we will forward your request to the relevant client and apply suppression on our infrastructure.

10. Sub-Processors

We engage a limited number of trusted vendors to help us deliver the services (for example: cloud hosting, email service providers and deliverability tools, scheduling tools such as Cal.com, CRM, accounting, and analytics). Each sub-processor is bound by appropriate confidentiality and data-protection obligations and processes personal data only on our documented instructions. An up-to-date list of our sub-processors is available on request by writing to hello@skala.so.

11. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), gives you specific rights regarding your personal information, including the right to know what personal information we collect, the right to request deletion or correction, the right to opt out of the sale or sharing of personal information, and the right not to be discriminated against for exercising your rights. Skala does not sell personal informationand does not share personal information for cross-context behavioral advertising as those terms are defined under the CCPA. To exercise your CCPA rights, contact us at hello@skala.sowith the subject line “CCPA Request”.

12. Data Processing Agreement

Where Skala acts as a processor on your behalf (for example, when we operate outbound campaigns under a service agreement), we will, on request, enter into a written Data Processing Agreement (“DPA”) that includes the terms required by applicable law (including, where relevant, Article 28 of the GDPR / UK GDPR). To request a copy of the current DPA, please email hello@skala.so.

13. Changes to this Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a new “Last updated” date. If the changes are significant, we will take additional steps to inform you.

14. Contact

For any question, request, or complaint about this Privacy Policy or the way we handle your personal data, please contact us at:

AFFLUENT DIGITAL L.L.C-FZ
Meydan Grandstand, 6th floor, Meydan Road
Nad Al Sheba, Dubai
United Arab Emirates
Email: hello@skala.so