1. Who we are and how to contact us
ACE is operated by Louis Clarke ("we", "us"). We are the data controller for the personal data described in this policy. Website: https://avatarscontentearnings.com. For anything to do with your data, email [CONTACT_EMAIL].
2. What we collect
- Application form data — what you enter on our /apply form: your first name, email address, WhatsApp number and your answers to the qualification questions. Answers are saved as you go, so we may hold a partial application if you don't finish it.
- Booking details — when you book a call through Calendly: your name, email, chosen time and any answers you give in the booking form.
- Technical data — your IP address (we store the approximate location derived from it: country, region and city, not the address itself), device type, browser and the pages you visit.
- Marketing source data — the ad or link you arrived from (UTM parameters and ad click IDs such as Meta's
fbclidor TikTok'sttclid). - Cookies and tracking pixels — see section 7.
We do not ask for, and please do not send us, sensitive data such as health, financial account or ID document details.
3. Why we use your data and our legal basis
| Purpose | Legal basis (UK GDPR / GDPR) |
|---|---|
| Reviewing your application, deciding whether it's a fit and holding your strategy call | Taking steps at your request before entering into a contract; our legitimate interest in running our business |
| Sending call confirmations and reminders by email or WhatsApp | Taking steps before a contract; legitimate interest |
| Measuring and improving our advertising (e.g. knowing which ad led to an application) | Our legitimate interest in understanding and improving our marketing — you can object and opt out at any time (see section 7) |
| Keeping our site secure and preventing abuse | Legitimate interest |
| Keeping records we are legally required to keep (e.g. for tax or to handle complaints) | Legal obligation |
4. Who we share data with
We use trusted service providers (processors) to run the site and our business. They only process data on our instructions:
- Meta Platforms (Facebook / Instagram Pixel) — ad measurement.
- Calendly — scheduling your call.
- Supabase — the database that stores your application.
- Vercel — hosting the website.
- Bunny.net — hosting and streaming the video on our homepage.
- WhatsApp and email providers — communicating with you about your application and call.
We may also share data where the law requires it, or with professional advisers under confidentiality. We do not sell your personal data.
5. International transfers
Some of the providers above are based, or store data, outside the UK and the European Economic Area (mainly in the United States). Where that happens we rely on recognised safeguards such as the UK International Data Transfer Agreement or the EU Standard Contractual Clauses, or the provider's participation in an approved data-transfer framework, so that your data receives a comparable level of protection.
6. How long we keep your data
We keep application and booking data for up to 24 months from your last contact with us, unless you ask us to delete it sooner (see section 8) or we need to keep it longer to meet a legal obligation. Technical logs are kept for a shorter period. If you become a customer, we keep your records for as long as needed to provide the service and to meet our legal and accounting duties.
7. Cookies and tracking
We use the Meta Pixel to understand which of our Facebook and Instagram ads lead to applications and bookings, and to show relevant ads. The Pixel sets cookies and sends Meta information about your visit (such as the pages you view, how much of our video you watch and, if you book a call, a hashed version of your email address for matching).
How to opt out:
- Block or delete cookies in your browser settings, or use a content/ad blocker — this stops the Pixel from running.
- Adjust your ad preferences in your Facebook or Instagram account (Settings → Ads / "Ad preferences"), including "Ads shown off Meta" and "Activity information from ad partners".
- Use your browser's private/incognito mode.
Our site also uses strictly necessary storage (for example, to carry your application to the booking page and to avoid counting the same booking twice); this doesn't track you across sites.
8. Your rights
Under data protection law you can ask us to:
- access the personal data we hold about you;
- correct anything inaccurate;
- delete your data ("right to be forgotten");
- restrict how we use it;
- object to processing based on legitimate interests, including direct marketing;
- receive a copy of the data you gave us in a portable format;
- withdraw consent at any time where we rely on it (this doesn't affect processing that happened before) — and object to our use of the Meta Pixel by opting out as described in section 7.
To exercise any of these, email [CONTACT_EMAIL]. We'll respond within one month. You also have the right to complain to a supervisory authority: in the UK, the Information Commissioner's Office (ico.org.uk); in the Netherlands, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl); or the authority in the country where you live.
9. Children
Our services are for adults. The site is not intended for anyone under 18 and we don't knowingly collect data from them. If you believe a child has given us personal data, contact us and we'll delete it.
10. Changes to this policy and contact
We may update this policy from time to time; the date at the top shows the latest version. If a change is significant, we'll make that clear on the site. Questions or requests: [CONTACT_EMAIL].
Governing law: this policy and any dispute about it are governed by the law of [COUNTRY], without affecting the mandatory data-protection rights you have where you live.