PRIVACY POLICY AND LEGAL DISCLAIMER – GRATTINI ACADEMY
Last updated: October 2026
1. Data Controller
This Privacy Policy is provided pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”). The data controller is Scratch Therapy Ltd, a company established in Cyprus (European Union), which owns the Grattini Academy brand (the “Controller”, “we”, “us”).
Contact: [email protected]
2. Personal Data We Collect
We collect only the data needed to provide our training services: your name and email address; billing details required for invoices and receipts; information about your purchases, course access and progress; and the content of the messages you send us. Card and payment details are handled directly by our payment service providers: we never see or store your full card number.
3. Purposes and Legal Bases
We process your data to:
• deliver the course you purchased, manage your account and give you access to the members’ area (performance of a contract, Art. 6(1)(b) GDPR);
• fulfil our tax, accounting and other legal obligations (Art. 6(1)(c) GDPR);
• answer your requests and protect the security of our services and platform (legitimate interest, Art. 6(1)(f) GDPR);
• send you newsletters and promotional emails, only if you have agreed to receive them (consent, Art. 6(1)(a) GDPR). You can unsubscribe at any time using the link in every email.
4. Who Receives Your Data
We do not sell or rent your personal data, and we do not share it with third parties for their own marketing purposes. To run our services we rely on trusted providers who process data on our behalf and only according to our instructions, such as our online course and website platform (Kajabi), our payment service providers and our email provider. Data may also be disclosed to public authorities where required by law.
Some of these providers are located outside the European Economic Area, for example in the United States. In such cases, transfers take place only with appropriate safeguards, such as the Standard Contractual Clauses approved by the European Commission or, where applicable, the EU–U.S. Data Privacy Framework.
5. Cookies
Our website uses technical cookies that are necessary for it to work (for example to keep you logged in to the members’ area). Any non-essential cookies are used only with your consent, which you can withdraw at any time through your browser settings.
6. Data Retention
We keep your data for as long as necessary to provide the course and manage your account, and in any case for the period required by applicable tax and accounting laws. Data processed on the basis of consent is kept until you withdraw it.
7. Your Rights
Under Articles 15–22 GDPR you have the right to access, rectify, erase, restrict and port your data, and to object to its processing. Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal. To exercise your rights, write to [email protected].
You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU Member State where you live or work.
8. Age Requirement
Our courses are intended for adults. We do not knowingly collect data from persons under 18.
9. Wellness Disclaimer – No Medical Purpose
Scratch Therapy is a holistic wellness practice based on gentle sensory stimulation of the skin. We state clearly that:
No medical value: the method does not involve or replace diagnosis, prevention, treatment or rehabilitation of any disease or condition. Operators and trainers do not practise any health profession.
No therapeutic claims: anyone using the method is strictly forbidden from attributing curative or therapeutic properties to Scratch Therapy. Anyone who does so is personally responsible and releases the Controller from any related claim, damage or dispute.
Personal responsibility: sessions are intended for people in good health. Anyone with a medical condition must consult their doctor beforehand.
10. Limitation of Liability
The Controller accepts no liability for direct or indirect damage arising from improper use of the Scratch Therapy protocol. Trained operators work with full professional autonomy and are personally responsible for how they apply the protocol, for respecting the Code of Ethics and for their relationships with their own clients. The Controller is not liable for conduct by trained operators that falls outside the official guidelines of the protocol.
11. Intellectual Property and Scientific Background
The Scratch Therapy protocol is an original work protected by copyright and intellectual property law. The method as a whole, including manuals, operating procedures, video courses, stimulation sequences and teaching materials, is the exclusive intellectual property of the Controller. Any unauthorised reproduction, distribution, modification or use, in whole or in part, is prohibited and will be pursued before the competent authorities.
The method draws on international neuroscience literature, in particular published research on C-tactile fibres. The biological mechanisms described in that research belong to the scientific community; our intellectual property lies in the original way this knowledge has been turned into a structured practice aimed at well-being.
12. Changes to this Policy
We may update this policy from time to time. The current version is always available on this page, with the date of the latest update shown at the top.
