Privacy Policy

1. Introduction

Hugo Bazan LLC, operating as Skala ("Skala", "we", "us", or "our"), is a digital advertising agency located at 651 N Broad St, Suite 201, Middletown, DE 19709, United States. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website skala.gg (the "Site") or interact with our services.

By using the Site, you agree to the collection and use of information in accordance with this policy. If you do not agree, please discontinue use of the Site.

2. Information We Collect

2.1 Information You Provide

• Contact form submissions (name, email address, company name, message)
• Recruitment application information (name, email, experience, portfolio links)
• Email correspondence when you contact us at admin@skala.gg

2.2 Automatically Collected Information

• Browser type, operating system, and device information
• IP address and approximate geographic location
• Pages visited, time spent on pages, and referral URLs
• Interactions with advertising content (clicks, impressions) via Meta Pixel and Google Tag Manager

2.3 Advertising Platform Data

As a performance advertising agency, we access and process advertising campaign data on behalf of our clients through official API integrations. All platform data is accessed solely to provide campaign management services under written agreements with each client, and is never used for our own advertising purposes or shared with unauthorized third parties.

• Meta Marketing API: We access Meta ad account data (campaigns, ad sets, creatives, audiences, and performance metrics) to create, manage, and optimize paid advertising campaigns on Facebook and Instagram on behalf of clients. Data accessed through the Meta platform is handled in accordance with Meta's Platform Terms and Data Policy.
• Google Ads API: We access Google Ads account data (campaigns, keywords, bids, conversions, and performance reports) to manage and scale paid search and display campaigns. Data is processed solely for client campaign optimization and reporting.
• TikTok Ads API: We access TikTok for Business account data (campaigns, creatives, audiences, and analytics) to manage paid social campaigns on TikTok. Data is used exclusively for client campaign management under TikTok's API Terms of Service.
• Taboola Backstage API: We access Taboola account data (campaigns, creatives, and performance metrics) to manage native advertising campaigns across Taboola's publisher network on behalf of clients.

3. How We Use Your Information

We use the collected information to:

• Respond to inquiries and provide requested services
• Process recruitment applications and evaluate candidates
• Operate, maintain, and improve the Site
• Analyze website traffic and user behavior (via Google Analytics / GTM)
• Measure advertising campaign effectiveness (via Meta Pixel)
• Manage client advertising campaigns programmatically through official APIs
• Monitor real-time performance metrics and generate automated reports for clients
• Comply with legal obligations and enforce our Terms of Service

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on the Site and hold certain information. Cookies in use include:

• Analytics cookies: Provided by Google Tag Manager / Google Analytics to understand how visitors interact with the Site.
• Advertising cookies: Meta Pixel tracks website events to measure ad campaign performance and enable remarketing.
• Functional cookies: Used to remember your preferences (e.g., dark/light theme).

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, some parts of the Site may not function properly if you disable cookies.

5. Third-Party Services

We use the following third-party services that may collect data:

• Vercel: Hosting provider. May process server logs including IP addresses. (Vercel Privacy Policy)
• Google Tag Manager / Google Analytics: Website analytics. (Google Privacy Policy)
• Meta (Facebook) Pixel: Advertising measurement and remarketing. (Meta Privacy Policy)
• Meta Marketing API: Used to manage advertising campaigns on behalf of clients.
• Google Ads API: Used to manage advertising campaigns on behalf of clients.
• TikTok Ads API: Used to manage advertising campaigns on behalf of clients via the TikTok for Business API portal.
• Taboola Backstage API: Used to manage native advertising campaigns on behalf of clients. (Taboola Privacy Policy)

6. Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. Contact form submissions are retained for up to 2 years. Advertising campaign data processed through APIs is retained per the data retention terms of each advertising platform and our client agreements.

7. Your Rights

You have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data, subject to legal obligations.
• Opt-out: Opt out of marketing communications at any time.
• Data portability: Request your data in a portable, machine-readable format.

To exercise any of these rights, contact us at admin@skala.gg. We will respond within 30 days.

8. GDPR & CCPA Compliance

8.1 European Users (GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom, you have rights under the General Data Protection Regulation (GDPR), including the right to access, rectify, erase, restrict, or object to processing of your personal data, and the right to data portability. Our lawful basis for processing personal data is: (a) your consent, (b) the performance of a contract, or (c) our legitimate interests in operating and improving our services. To exercise your GDPR rights, contact us at admin@skala.gg.

8.2 California Residents (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your personal information, and the right to opt out of the sale of personal information. We do not sell your personal information to third parties. To exercise your CCPA rights, contact us at admin@skala.gg or by mail at 651 N Broad St, Suite 201, Middletown, DE 19709.

9. Data Security

We implement commercially reasonable technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no transmission over the Internet or electronic storage method is 100% secure. We cannot guarantee absolute security of your data.

10. Children's Privacy

The Site is not directed at individuals under the age of 16. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us at admin@skala.gg and we will take steps to remove such information.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the "Last updated" date at the top of this page. We encourage you to review this policy periodically.

12. Contact Us

For privacy-related inquiries or to exercise your data rights, contact us at: