For businesses that want to test paid advertising and start generating enquiries.
What’s included: — Initial audit & strategy — Setup of 1 ad platform (Meta, TikTok, or Google) — 2–3 ad campaigns launched — Weekly optimisation & performance tracking Not included: — Content creation — Social media management Best for: Testing ads and validating demand
For businesses that want a reliable system for attracting clients.
What’s included: — Everything in Ads Start — Social media management (1–2 platforms) — 8–12 short-form videos per month — Video editing & basic scripting — Posting & account management Best for: Building a consistent flow of enquiries
For businesses ready to grow faster and increase revenue.
What’s included: — Multi-platform ads (Meta + TikTok + Google) — Full social media management — 15–20 short-form videos per month — Creative direction, scripting & editing — Priority optimisation & faster scaling For clients in Ireland: — On-site photo & video production available Best for: Scaling what already works
Effective Date: 17 April 2025 | Last Updated: 17 April 2025
1. Introduction and Identity of the Data ControllerWelcome to Grably ('we', 'us', 'our'). Grably is a performance marketing and digital advertising agency offering services including paid advertising campaign management across Meta (Facebook/Instagram), TikTok, and Google, as well as social media management and content creation. Grably operates primarily in Ireland and serves clients across the European Union and internationally. As a company conducting business activities directed at persons in Ireland and the EU, we act as a Data Controller within the meaning of Regulation (EU) 2016/679 (the General Data Protection Regulation, 'GDPR') and the Irish Data Protection Acts 1988–2018 (as amended by the Data Protection Act 2018, which implements the GDPR in Ireland). Contact details of the Data Controller: • Company name: Grably • Website: https://grably.tilda.ws • Email: hello@grably.pro If you have questions about how we handle your personal data, please contact us using the details above. 2. Scope and ApplicabilityThis Privacy Policy applies to: • Visitors to our website https://grably.tilda.ws; • Prospective and current clients who contact us via our website contact form, email, or telephone; • Business contacts and partners with whom we interact professionally. This Policy applies regardless of where you are located; however, if you are located in the European Economic Area (EEA) — including Ireland — you have specific rights under the GDPR described in Section 9 below. 3. Legal Basis for Processing (GDPR, Article 6)We only process your personal data where we have a lawful basis to do so. The legal bases we rely on are: 3.1 Contractual Necessity (Art. 6(1)(b) GDPR)Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. This applies when you engage Grably to provide advertising services. 3.2 Legitimate Interests (Art. 6(1)(f) GDPR)Processing is necessary for our legitimate business interests, provided these are not overridden by your interests, rights, or freedoms. Our legitimate interests include responding to business enquiries, marketing our services to business contacts, and improving our service offering. 3.3 Consent (Art. 6(1)(a) GDPR)Where we rely on your consent (e.g. for sending marketing communications), you may withdraw your consent at any time by contacting us at hello@grably.pro. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. 3.4 Legal Obligation (Art. 6(1)(c) GDPR)Processing may be necessary for compliance with a legal obligation to which we are subject (e.g. tax and accounting obligations). 4. Categories of Personal Data We CollectWe collect and process the following categories of personal data: 4.1 Data You Provide Directly• Name and surname; • Company name; • Email address; • Phone number; • Monthly advertising budget (if provided); • Information about your business submitted via our contact form or enquiry. 4.2 Data Collected AutomaticallyWhen you visit our website (hosted on Tilda Publishing), certain data may be collected automatically, including: • IP address; • Browser type and version; • Pages visited and time spent on pages; • Referring URL; • Device and operating system information. This data is collected through cookies and similar tracking technologies deployed by Tilda Publishing and our advertising platforms (see Section 7). 5. Purposes of ProcessingWe process your personal data for the following purposes: • Responding to enquiries submitted via the contact form or by email; • Assessing whether we can provide services suited to your needs; • Entering into and performing contracts for advertising services; • Managing and optimising your paid advertising campaigns (Meta, TikTok, Google); • Sending you information about our services where you have consented or where we have a legitimate interest; • Improving our website, services, and client experience; • Complying with legal and regulatory obligations; • Establishing, exercising, or defending legal claims. 6. Sharing and Disclosure of Personal DataWe do not sell your personal data. We may share your data with the following categories of recipients: 6.1 Advertising Platforms (Third-Party Processors)In order to manage and run advertising campaigns on your behalf, we interact with the following platforms, each of which processes data in accordance with their own terms and privacy policies: • Meta Platforms Ireland Ltd (Facebook, Instagram) — headquartered in Dublin, Ireland; subject to EU data protection law as an EEA entity; • TikTok Technology Limited (operating entity for EEA users) — Ireland; TikTok may transfer data internationally; see TikTok's Privacy Policy; • Google Ireland Limited (Google Ads, YouTube) — headquartered in Dublin, Ireland; subject to EU data protection law. Where these platforms transfer data outside the EEA, they rely on Standard Contractual Clauses (SCCs) approved by the European Commission or other appropriate safeguards under Chapter V of the GDPR. 6.2 Service Providers and Subprocessors• Tilda Publishing (website hosting platform) — processes data as a data processor on our behalf; • Email service providers for business communication; • Accounting and legal advisors, where necessary for compliance. 6.3 Legal RequirementsWe may disclose personal data to competent authorities (including An Garda Siochana, the Revenue Commissioners, or other public bodies) where required by applicable Irish or EU law. 7. Cookies and Tracking TechnologiesOur website uses cookies and similar tracking technologies. Cookies are small text files stored on your device. Categories of cookies used on our website may include: • Strictly necessary cookies — required for the website to function; • Analytics cookies — to understand how visitors interact with the site (e.g. Tilda's built-in analytics); • Marketing/advertising cookies — placed by Meta Pixel, TikTok Pixel, or Google Tag Manager to enable campaign tracking and retargeting. You may control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the website. You may also opt out of interest-based advertising through industry tools such as the Digital Advertising Alliance (DAA) or the European Interactive Digital Advertising Alliance (EDAA) at https://www.youronlinechoices.eu/. We will seek your consent for non-essential cookies in accordance with the requirements of the Irish ePrivacy Regulations 2011 (S.I. No. 336 of 2011), which implement the EU ePrivacy Directive (Directive 2002/58/EC, as amended). 8. International Data TransfersGrably is based in Ireland and the EEA. Some of our third-party service providers and advertising platforms (including TikTok and certain Google infrastructure) may transfer and process personal data outside the EEA, including to the United States. Where such transfers occur, we ensure that appropriate safeguards are in place in accordance with Chapter V of the GDPR, including: • Standard Contractual Clauses (SCCs) adopted by the European Commission (Commission Implementing Decision (EU) 2021/914); • Adequacy decisions of the European Commission, where applicable; • Binding Corporate Rules (BCRs), where applicable. You may request further information about the safeguards applicable to specific transfers by contacting us at hello@grably.pro. 9. Your Rights Under GDPR (EEA/Irish Users)If you are located in the EEA (including Ireland), you have the following rights under the GDPR: • Right of access (Art. 15 GDPR) — to obtain confirmation of whether we process your personal data and to receive a copy; • Right to rectification (Art. 16 GDPR) — to have inaccurate data corrected; • Right to erasure (Art. 17 GDPR) — to have your data deleted ('right to be forgotten'), subject to legal exemptions; • Right to restriction of processing (Art. 18 GDPR) — to restrict how we use your data in certain circumstances; • Right to data portability (Art. 20 GDPR) — to receive your data in a structured, commonly used, machine-readable format; • Right to object (Art. 21 GDPR) — to object to processing based on legitimate interests, including for direct marketing; • Rights related to automated decision-making (Art. 22 GDPR) — not to be subject to solely automated decisions that significantly affect you. To exercise any of these rights, please contact us at hello@grably.pro. We will respond within one calendar month. If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission of Ireland (DPC): • Website: https://www.dataprotection.ie • Phone: +353 57 868 4800 • Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland 10. Data RetentionWe retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Our general retention periods are: • Client enquiries and pre-contractual communications: up to 2 years from the date of last contact if no contract is concluded; • Contract and service-related data: for the duration of the contract and up to 7 years thereafter, in accordance with Irish tax and accounting obligations (Taxes Consolidation Act 1997); • Marketing contacts (consent-based): until consent is withdrawn; • Website analytics data: as determined by Tilda Publishing's data retention policy. 11. Data SecurityWe implement appropriate technical and organisational measures to protect your personal data against accidental loss, destruction, damage, unauthorised access, disclosure, or alteration, in accordance with Article 32 of the GDPR. These measures include secure communication channels (TLS/HTTPS), access controls, and data minimisation practices. Where third-party processors handle your data, we ensure they are bound by appropriate data processing agreements under Article 28 GDPR. 12. Children's DataOur services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us at hello@grably.pro so that we may promptly delete it. 13. Changes to This Privacy PolicyWe may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. We will indicate the date of the last update at the top of this document. Where changes are material, we will take reasonable steps to notify you. We encourage you to review this Policy periodically. Your continued use of our website after the effective date of any changes constitutes acceptance of the updated Policy. 14. Contact UsIf you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact us: • Email: hello@grably.pro • Website: https://grably.tilda.ws
Grably | Privacy Policy | Version 1.0 | April 2025
This document is governed by Irish law and EU Regulation 2016/679 (GDPR).
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