Privacy Policy

Effective and last updated: November 9, 2026

This Privacy Policy explains what personal information we collect, why we collect it, who we share it with, how long we keep it and what you can ask us to do with it. It covers this website, our booking pages, our advertising, and the Messenger conversations that start when you click one of our Facebook or Instagram ads.

1. Who We Are

This website and these services are run by Gabriël ten Have, trading as Scale Annuities (At Higher Scale), based in Belgium. Scale Annuities provides client acquisition and marketing services to independent annuity and insurance advisors. We are the data controller for the personal information described in this Policy.

For anything about your privacy or your data, write to athigherscale@gmail.com. That address reaches us directly and is the fastest way to get a response.

We do not sell insurance or annuity products, and we do not give financial, insurance, tax or legal advice to consumers.

2. What We Collect

When you message us from a Facebook or Instagram ad

If you click one of our ads and the conversation opens in Messenger, Meta gives us the public profile information attached to your account. An automated assistant then asks you a short set of questions, and we keep your answers.

Meta calls this lead generation data, meaning the information you elect to send us through the lead feature: your name, your email address and any additional information you choose to give us in the chat. Everything in the list below is lead generation data, and we treat it that way throughout this Policy.

Your name and the Facebook or Messenger profile information Meta shares with us, such as your profile picture and your page-scoped ID.
Your answers to our qualification questions, which ask how much annuity premium you currently write and what budget you have available to scale your client acquisition.
Any phone number or email address you choose to share in the chat so we can follow up outside Messenger.
The messages themselves, including anything else you tell us about your practice while we talk.

You decide what to answer. If you would rather not share a phone number or an email address, say so and we will keep the conversation in Messenger.

When you use this website, a form or a booking page

Contact details you enter, such as your name, email address, phone number, business name and website.
Business information you choose to share, such as premium written, average case size, cost per lead, show-up rate and details of your current marketing.
Your answers to our 2-minute funnel audit, and the result it produces for you.
Your appointment details when you book a call, including the time slot and the time zone you are in.
Content you send us for our services, such as photos, video and voice recordings used, with your written consent, to create AI likeness content for your advertising.
Our correspondence with you, including emails, messages, call notes and meeting recordings where you have been told the call is being recorded.

What we never ask for

We do not ask for or collect sensitive personal information, in the Messenger chat, on our forms or on our booking pages. That means no health or medical information, no bank account, card or other financial account details, no government identification numbers such as a Social Security number, passport or national ID, and no information about race, ethnicity, religion, political opinions, trade union membership, sexual orientation, criminal history or biometric data. Meta's Advertising Standards prohibit collecting these through a lead feature, and we have no use for them. The questions we ask are about your business: premium written and the budget you have to scale. If you send us something in a sensitive category anyway, we delete it and ask you not to send it again.

Collected automatically

Device and usage data such as IP address, browser and device type, pages viewed, referring URL, and the date and time of your visit.
Information from cookies, pixels and similar technologies, described in section 6.

3. How We Use It

To reply to you in Messenger and keep the conversation going.
To send you the video or other material you asked for.
To follow up with you about our client acquisition services for annuity advisors, by Messenger, email, phone or text, depending on what you shared and agreed.
To work out whether what we do is a fit for your practice, which is what the qualification questions are for.
To schedule, confirm and remind you about a call, and to let you reschedule or cancel.
To deliver and support the services you buy from us.
To measure and improve our advertising, and to operate, secure and improve this website.
To meet our legal obligations and to protect our rights.

What we said we would do, and nothing else. The call to action you responded to is a simple one: we reply to you in Messenger, we send you the video you asked for, and we follow up with you about our client acquisition services for annuity advisors. That is the purpose we collected your information for, and that is what we use it for. If we ever wanted to use it for something materially different, we would ask for your consent separately first, and you would be free to say no.

No automated decisions with legal effect. Our Messenger assistant asks questions and sorts conversations so a human knows where to pick them up. It does not make any decision that has a legal effect on you or that significantly affects you in any other way. A person reviews every conversation and decides what happens next.

4. Our Legal Bases Under the GDPR

Because we are based in Belgium, the EU General Data Protection Regulation applies to what we do. We rely on two legal bases, and we tell you which one covers what.

Consent. When you start a chat with us, fill in a form, book a call or ask for a video, you are choosing to give us your details for that purpose, and we handle them on the basis of that consent. You can withdraw it at any time, and we stop.
Legitimate interest. We have a genuine business interest in contacting annuity and insurance professionals about a service built for their industry, in following up on a conversation you started, and in measuring and improving our own advertising and website. We rely on this only where it does not override your rights, and you can object at any time.

5. Who We Share It With

We never sell your personal information. Lead generation data from Messenger is never sold, rented or traded to anyone, for any amount, and we never share your phone number or your messaging consent with anyone for their own marketing.

We share your information only with the service providers who help us run the service, and each of them may use it solely to fulfil the purpose we collected it for, the one described in section 3. They act on our instructions, they handle your data under their own privacy terms and under contracts that hold them to that limit, and none of them is permitted to use your information for its own purposes, to build its own products or to market to you.

Meta Platforms (Facebook, Instagram and Messenger), which carries the conversation and measures our ads.
Our CRM and marketing automation, such as GoHighLevel, which stores your contact record and sends our follow-up.
Video hosting, such as Loom, which delivers the videos we send you.
Scheduling and calendar tools, including our own booking calendar and the email reminders that go with it.
Hosting and infrastructure, Cloudflare, Inc., which serves this website and stores form, audit and booking records.
Email delivery and conferencing, which send our messages and host our calls.
Payment providers, if you become a client and pay us. We never see or store your full card details.
Analytics, described in section 6.

We also disclose information where the law requires it, such as a court order or a lawful request from an authority, to protect our rights, property or safety or those of others, and to a buyer if the business is ever sold, in which case this Policy still applies.

6. Cookies, Pixels and Advertising

We use cookies and similar technologies to run this website, to understand how it is used, and to measure our advertising.

Meta (Facebook and Instagram). We use the Meta Pixel and Conversions API, which may collect information about your visit and your actions on this site so Meta can measure our ads and show them to people who may be interested. Meta processes this under its own Privacy Policy, and you can change what you see in your Meta ad settings.
Google. We use Google Ads conversion tracking and remarketing, and Google Analytics. Google explains its role at How Google uses information from sites that use its services. You can opt out through Google Ad Settings or the Google Analytics opt-out browser add-on.
Microsoft Clarity. We use Microsoft Clarity to see how visitors use this site, through heatmaps and recordings of clicks, scrolling and mouse movement. Clarity masks what you type into forms by default. Microsoft processes this under its own Privacy Statement.
Funnel audit and booking calendar. Your audit answers, your contact details and your appointment are stored by Cloudflare, Inc., which hosts this website, and emailed to us so we can follow up. We set no advertising cookies in the booking calendar.
Industry opt-outs. You can opt out of interest-based advertising from participating companies at optout.aboutads.info and optout.networkadvertising.org.
Browser controls. Most browsers let you block or delete cookies, though blocking some may change how the site works. Where the law requires it, we honor Global Privacy Control signals as an opt-out of sale or sharing for targeted advertising.

7. How Long We Keep It

We keep lead information, including your Messenger conversation and your answers to our questions, for 24 months after our last contact with you. If you have not replied and we have not spoken in that time, we delete it. Every time you contact us again, the 24 months start over.

Two things are treated differently. If you become a client, we keep your records for as long as we work together and then for as long as Belgian accounting and tax law requires, which is seven years for invoices and payment records. And if you ask us to stop contacting you, we keep the minimum needed to honor that, which is your email address or phone number on a suppression list, so that we do not contact you again by mistake.

You can ask us to delete your information sooner at any time, and we will unless the law requires us to keep it.

8. Your Rights Under the GDPR

If the GDPR applies to you, you have the right to:

Access your personal information and get a copy of it.
Correct anything that is wrong or out of date.
Delete your personal information, often called the right to be forgotten.
Object to our processing where we rely on legitimate interest, including our marketing. If you object to marketing, we stop, with no questions asked.
Restrict our processing while a question about your data is being sorted out.
Withdraw your consent at any time, which does not affect anything we did lawfully before you withdrew it.
Receive your data in a portable format that you can take elsewhere.

To use any of these rights, email athigherscale@gmail.com with "Privacy Request" in the subject line. We answer within 30 days, and we may ask a question first to confirm it is really you.

If you are not happy with how we handled it, you can complain to the Belgian Data Protection Authority: Gegevensbeschermingsautoriteit / Autorité de protection des données, Rue de la Presse 35, 1000 Brussels, Belgium, contact@apd-gba.be, www.dataprotectionauthority.be. If you live elsewhere in the EEA or in the UK, you can complain to your own supervisory authority instead.

9. If You Live in the United States

Many of the advisors we speak to are in the United States. If you live in California or in another US state with a privacy law, you have rights that work much like the ones above.

Know what categories of personal information we collected about you, where it came from, why we collected it and who we disclosed it to.
Access the specific pieces of personal information we hold about you.
Correct inaccurate personal information.
Delete the personal information we hold about you.
Opt out of targeted advertising, profiling and any sale or sharing of personal information.
Limit the use of sensitive personal information. We do not ask you for sensitive personal information, and we do not use it to infer anything about you.
No retaliation. We will never give you a worse price or a worse service because you used one of these rights.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined in the CCPA and CPRA. We have not done so in the last twelve months, and we do not knowingly collect or sell the personal information of anyone under 16.

Send US privacy requests to the same address, athigherscale@gmail.com, with "Privacy Request" in the subject. You may use an authorized agent, and you may appeal our decision by replying to our answer.

10. How to Stop Hearing From Us

You can end the conversation at any point, and it is meant to be easy.

In Messenger, reply STOP. We stop messaging you there. You can also block or report the conversation from inside Messenger.
By email, click the unsubscribe link in any of our emails, or write to athigherscale@gmail.com and ask us to stop.
By text, reply STOP to opt out or HELP for help. Message frequency varies, and message and data rates may apply. Agreeing to receive messages is never a condition of buying.

Whichever route you use, we add you to our suppression list so you are not contacted again by mistake.

11. How We Keep It Safe

We use appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, and against accidental loss, destruction or damage.

In practice that means your information sits with established providers that encrypt data in transit and at rest, access is limited to the people who need it to do the work, accounts are protected with strong passwords and two-factor authentication wherever the provider supports it, and we delete what we no longer need.

No system is completely secure, so we cannot promise absolute security. If a breach ever affected your data, we would notify you and the Belgian Data Protection Authority as the GDPR requires.

12. Sending Data Outside Europe

We are in Belgium, and several of the providers listed in section 5, including Meta, Cloudflare, GoHighLevel and Loom, are in the United States. That means your information is transferred outside the European Economic Area. Those transfers are covered by the European Commission's Standard Contractual Clauses or, where the provider is certified, the EU-US Data Privacy Framework, and we check that each provider offers safeguards appropriate for the data involved. Ask us at athigherscale@gmail.com and we will tell you which mechanism covers which provider.

13. Children and Minimum Age

Our ads, our Messenger conversations, this website and our services are intended for adults aged 18 and over, and specifically for licensed insurance and annuity professionals. We do not target our lead ads or any other advertising to minors, and we do not market to children in any way.

We do not knowingly collect personal information from anyone under 18. If we receive information from someone under 18, we delete it. If you are a parent or guardian and you believe your child has given us information, email athigherscale@gmail.com and we will delete it promptly.

14. Other Websites

We link to other sites and tools, such as Meta platforms, our scheduling pages and video hosting. Once you are there, their own privacy policies apply, not ours.

15. Changes to This Policy

If we change this Policy, we post the new version on this page and update the date at the top, so you can always see when it last changed. If a change is significant, for example a new purpose for your data or a new category of provider, we say so clearly at the top of this page for at least 30 days, and we email anyone whose data we hold under consent before the change takes effect.

16. How to Reach Us About Your Data

If you have a question about how we use your lead information, or you want to use any of the rights in this Policy, contact us and we will answer you. A person reads every one of these messages.

Email: athigherscale@gmail.com. This is our privacy address and the fastest way to reach us.
On Facebook: message the Scale Annuities page, or simply reply in the Messenger conversation you already have with us.
General enquiries: contact@scaleannuities.com.

We answer every privacy question within 30 days, and usually much sooner. If a request is complicated and we need more time, we tell you why before those 30 days are up.

Gabriël ten Have
Scale Annuities (At Higher Scale)
Belgium