Introduction Growth Strategy, Inc. ("Growth Strategy," "we," or "us") is a website development agency, website design agency and software application development agency who also integrates cloud-based product-analytics platform that helps customers build better products and helps grow their revenue. Growth Strategy respects the privacy of individuals and is committed to protecting the information of visitors to the website ("Visitors") and individuals or entities that register to use the Growth Strategy products and services through the Website ("Customers"). This Privacy Notice describes Growth Strategy’s practices for collecting, using, maintaining, protecting, and disclosing information in relation to Visitors of the website, Growth Strategy.com, including our Community Forum and Growth Strategy Academy ("Website"), Growth Strategy’s marketing activities, and Customers accessing and using the products and services available on the Website (collectively, "Product"). Please read the following carefully to understand our policies and practices regarding your information collected through the Website, through your use of the Product, through our marketing activities and how we will treat it. If you do not agree with the below policies and practices, your choice is not to use our Website or register to use the Product through our Website.
What This Privacy Notice Covers This Privacy Notice covers how we treat Personal Data that we gather when you access or use our Product. Specifically, Growth Strategy is the controller of your Personal Data as described in this Privacy Notice, when it collects personal information from: (i) Visitors to Growth Strategy’s publicly available Website; (ii) Customers when our Customers register to use any product or service through the Website or access their account through Growth Strategy’s account portal and when we receive personal information from you related to our marketing activities. For clarity, this Privacy Notice does not apply when Growth Strategy processes Personal Data in the role of a processor on behalf of its Customers, including with respect to the processing of our Customer End User Data (as defined below). In addition, this Privacy Notice does not apply to the mobile applications, websites or services offered by our Customers or other third-parties. Throughout this Privacy Notice, "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations.
Personal Data We Collect And How We Use The Personal Data 3.1 PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
The Personal Data you provide to us directly
You provide to us your Personal Data when you voluntarily fill in forms on our Website such as when you request a demo or to contact sales. This Personal Data may include: first and last name, company name, job title, work email address, phone number and the content of your request. You may also share Personal Data with us through our Website when you sign up to register for an event, to receive our newsletter, subscribe to our blog, register to contribute and participate in our Community Forum, register for an event, to receive our newsletter, subscribe to our blog, register for an online webinar, download a white paper, playbook, or complete a survey. This Personal Data may include: first and last name, company name, job title, work email address, phone number and the content of your request. In order to access and use our products and services, you are required to register for an account with us. When you register for an account, you may provide Personal Data to us, including first and last name, email address, company name, telephone number, physical address, username and password. In order to participate in Growth Strategy’s start-up scholarship program, you may provide your credit card or other payment details information directly to our third party payment processor. As explained below, Growth Strategy does not store this information. You may also provide Growth Strategy with your personal information at a marketing event. This Personal Data may include: first and last name, company name, job title, work email address, phone number and the content of your request. The Personal Data we collect from third party sources
Growth Strategy may obtain Personal Data about you from third parties, including, but not limited to, marketing event organizers, partners and resellers. This information may include your first and last name, company name, job title, work email address, phone number and address. Growth Strategy requires that any third party providing it with information has obtained the information lawfully and the third party has obtained the appropriate consent to share the information with Growth Strategy. Service providers. For example, we may use third party providers of business contact information. The Personal Data provided by these Service providers to us about you may include your business mailing addresses, job titles, business email addresses and business phone numbers, and LinkedIn URLs for purposes of delivering relevant email content, advertisements and events. Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services, related to how you interact with our Website, event promotions, advertisements or communications. Information We Collect Automatically:
As you navigate through and interact with our Website or Product or authorized representatives and staff interactions, we may use cookies, which are small files placed on the hard drive of your computer or mobile device, and web beacons, which are small electronic files located on pages of the Website, to collect certain information about your equipment, browsing actions, and patterns. We also use cookies to access information when you sign in, store your preferences, to keep you logged in, and to store a limited amount of behavioral data. The data automatically collected from cookies and web beacons may include information from your Web browser (such as browser type and browser language) and details of your visits to our Website, including traffic data, location data and logs, page views, length of visit and website navigation paths as well as information about your computer and internet connection, including your IP address and how you interact with our Products and services.. We collect this data in order to help us improve our Website, the Product and the user experience with our Website and Product and also to enhance your customer experience.
Growth Strategy currently does not support Do Not Track signals set by your browser because there is not an industry or legal standard for these signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. The information we collect automatically may also include statistical and performance information arising from our Customers’ use of our Products and services and Visitors to our Website. This type of data will only be used by us in an aggregated and anonymized manner. You can decide whether or not to accept cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending upon the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You can also delete all cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and the Product, Website and functionalities may not work. To explore what cookie settings are available to you, look in the "preferences" or "options" section of your browser’s menu. To find out more information about cookies, including information about how to manage and delete cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or https://www.allaboutcookies.org/
. 3.2 THE WAY Growth Strategy USES YOUR PERSONAL DATA
We use information that we collect about you or that you provide to us, including Personal Data, in order to respond to a request from you, to carry out our legal obligations, to fulfill a contract with you, to protect your vital interests, to provide you with notices and for other purposes with your consent as described below. We use the Personal Data you provide to us when you fill in forms on our Website to respond to your request and to contact you about that request. Our legal basis for processing this personal information is our legitimate interest in communicating with you and fulfilling your requests. We may use your Personal Data to provide the Product to you as well for non-marketing or administrative purposes (such as notifying you of major changes to the Website, the Product or for customer service purposes). Our legal basis for processing this Personal Data is in the performance of our contract to provide the Product or other services to you. We also use the Personal Data you provide to us for the purpose of operating our Website, ensuring the security and integrity of our Website and Product and maintaining back-ups of our databases. Our legal basis for processing this personal information is our legitimate interests, namely the proper administration of and security of our Website and Product. For Personal Data and information that we collect through tracking technologies about your interaction with our Website and Product, we use this information for analyzing the use of the Website and Product in order to improve the quality and design of our Website and the user experience with our Website and Product. Our legal basis for processing this type of data is our legitimate interests, namely, to provide you with a better user experience. We may use the Personal Data you provide to us at marketing events, when you register for an online webinar or download a whitepaper for the purpose of offering, marketing and selling products and services to you. Our legal basis for processing this Personal Data is consent, which you can withdraw at any time. We may also use any of your Personal Data identified in this Privacy Notice for the purposes of: (i) enforcing our agreements and policies, including Terms of Service or Master Service Agreement, (ii) protecting or defending Growth Strategy’s legal rights; (iv) protecting your vital interests or the vital interests of another natural person; or (v) complying with a legal obligation. We may use your Personal Data for any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the "CCPA"). We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice. As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Product or Website. Also, we may receive a confirmation when you open an email from us, which helps us improve our Website and Product. If you do not want to receive communications from us, please indicate your preference by emailing us at privacy@Growth Strategy.com or ccpa@Growth Strategy.com.
Growth Strategy has not sold your Personal Data over the last twelve (12) months and Growth Strategy does not sell Personal Data. For purposes of this section, we use the term ‘sell’ as it is defined in the CCPA.
Customer End User Data This Privacy Notice does not apply to Customer End User Data or Customer Applications. With respect to Growth Strategy’s Customers, Growth Strategy is a processor, and Growth Strategy processes the Personal Data collected by our Customers and sent to the Growth Strategy platform only in accordance with the instructions of our Customers. Our Customers may integrate into their mobile applications, websites or other services (collectively, "Customer Applications") certain aspects of our Product in order to understand how their own users ("Customer End Users") engage with the Customer Applications ("Customer End User Data"). Our Customers, not Growth Strategy, choose the type of Customer End User Data collected by Customer Applications, and processed, transferred and stored through our Customers’ use of the Products. We process the Customer End User Data only according to the instructions of Customers and, our legal obligations with respect to the Customer End User Data is set forth in the agreement between us and our Customers. The collection of Customer End User Data through Customer Applications is governed by our Customers’ privacy policies, and if you are a Customer End User then you should review the Customer’s privacy policy to learn more about the Customer’s data handling practices. While Growth Strategy recognizes that an individual has the right to access, delete and amend the data collected about that individual, Growth Strategy does not have a relationship with the Customer End Users but rather only with our Customers. If you are a Customer End User and you would like to access, amend or delete your data, then you need to contact the Customer directly and Growth Strategy will respond within a reasonable period of time to any such request by our Customer. Growth Strategy only retains the Customer End User Data we process on behalf of our Customers for as long as necessary to provide the Product to our Customers or as required to comply with legal obligations, resolve disputes and enforce any agreement.
International Transfer By interacting with the Website or using the Product, you understand that your Personal Data may be transferred to the United States or another country other than your country of residence and you consent to such transfer. In order to ensure that your Personal Data receives an adequate level of protection and security, Growth Strategy has implemented appropriate safeguards for cross-border transfers of Personal Data, as required by applicable data protection laws. These safeguards include using the European Commission-approved standard contractual clauses to protect the transfer of your Personal Data to Growth Strategy’s corporate affiliates or service providers, if required by applicable law. Growth Strategy also remains self-certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. However, it is not currently relying on these frameworks for the transfer of Personal Data. Growth Strategy complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Data transferred from the European Union, and the United Kingdom and Switzerland to the United States, respectively, in reliance on Privacy Shield. Growth Strategy has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view the certification for Growth Strategy, please visit: https://www.privacyshield.gov/. For the actions of third party agents Growth Strategy engages to process data on our behalf, Growth Strategy remains responsible and liable under the Privacy Shield Principles if a third party agent processes the Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Growth Strategy proves that it is not responsible for the event giving rise to the damage.
Our Commitment To Data Security Growth Strategy uses commercially reasonable physical, managerial, and technical safeguards designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is also encrypted and stored on our secured servers behind firewalls. However, you are also responsible for maintaining the confidentiality of your password and other information used by you to access the Website or use the Product. While Growth Strategy does its best to protect your Personal Data, Growth Strategy cannot guarantee the security of your Personal Data transmitted to our Website because the transmission of information via the internet is not completely secure. Any transmission of your Personal Data is done at your own risk and Growth Strategy cannot guarantee that such Personal Data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your Personal Data or information. If Growth Strategy learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Growth Strategy may post a notice on the Website if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us at privacy@Growth Strategy.com.
Choices About How We Use And Disclose Information We Collect From You We strive to provide you with choices regarding the Personal Data you provide to us and we understand that you have the right to access, correct, delete, object to and restrict our use of your Personal Data. We also understand that you have the right to obtain a copy of your Personal Data from us and to withdraw your consent of the processing of your Personal Data by us. Please note that the rights set forth in this Section 8 apply globally to all Visitors and Customers, whether or not you are a California resident or a resident of the European Union, United Kingdom, Lichtenstein, Norway or Iceland. We have created mechanisms to provide you with the following control over your Personal Data: You may choose not to provide Personal Data through our Website or when you register for the Product, in which case Growth Strategy may not be able to provide certain services to you or respond to your requests. You can access, review and change your Personal Data by logging into your account on the Website and visiting your account profile page. You may also send us an email at privacy@Growth Strategy.com or ccpa@Growth Strategy.com to request access to, correct or delete any Personal Data that you have provided to us. In some cases, we may not be able to delete your Personal Data except by also deleting your user account. If you do not wish to have your email address or other contact information used by us to promote our own products or services, you can opt-out by checking the relevant box located on the form on which we collect your Personal Data or at any time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to privacy@Growth Strategy.com. If we have sent you a promotional email, you may unsubscribe to receive future emails via the unsubscribe link in that email or adjust your user preferences in your account profile as noted above. The opt out specified above does not apply to information provided to us as a result of a purchase, product service experience or other transactions. You may also request a copy of your Personal Data that you have provided to us directly by sending an email to privacy@Growth Strategy.com or ccpa@Growth Strategy.com. We will provide you a copy of your Personal Data in a commonly used electronic form. Please note to exercise the rights set forth above we may will ask you to: (1) provide sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request. We will work to respond to your Valid Request within 30 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. You may submit a Valid Request by emailing us at privacy@Growth Strategy.com or ccpa@Growth Strategy.com
We will not discriminate against you for exercising your rights under the GDPR, CCPA or other applicable data privacy laws or regulations. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the GDPR, CCPA or other applicable data privacy laws or regulations.
Personal Data that Growth Strategy collects and processes as a controller for the purposes identified in this Privacy Notice are not kept by Growth Strategy for longer than is necessary for the specific purpose identified in this Privacy Notice unless Growth Strategy is required to retain your Personal Data for a longer period of time to comply with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws or regulations), resolve disputes, and enforce our legal agreements and policies. Personal Data that Growth Strategy processes on behalf of its Customers as a processor is retained for the period of time specified in the agreement between Growth Strategy and its Customers, unless Growth Strategy is required to retain the Personal Data for a longer period of time to comply with our legal obligations (for example, if we are required to retain your personal information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 9.2 Children’s Privacy
Growth Strategy does not knowingly collect or solicit Personal Data directly from Visitors of the Website that are under the age of 13. If you are under 13, please do not provide or send us any Personal Data or attempt to register for or otherwise use the Product. If we learn that a child under 13 has directly provided us with their Personal Data through the Website, then we will delete that information. If you believe a child under 13 has registered for an account on the Website, please contact us at privacy@Growth Strategy.com. 9.3 Automated Decision-Making
Growth Strategy does not use any Personal Data provided by you for the purpose of automated decision-making. 9.4 Other Websites; Links
Our Website may contain links to other third party websites or applications (such as Facebook, LinkedIn or Twitter). This Privacy Notice does not apply to any third party websites, including through any application that may link to or be accessible from or on the Website, and Growth Strategy is not responsible for the privacy policies and the content of the third party websites or applications.
Updates And Changes To The Privacy Notice Please note that we reserve the right, at any time, to add to, change, update, or modify this Privacy Notice. If, in our reasonable discretion, the changes are material, we will post a notice on our website or send you an email. The modified Privacy Notice will be posted on this website along with the effective date. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes. Changes to this Privacy Notice are effective when they are posted on this page.
Disputes As part of our commitment to the Privacy Shield Principles, if you are a resident of the European Union or Switzerland and you have a privacy or data use concern, please contact Growth Strategy directly at privacy@Growth Strategy.com and Growth Strategy will use its best efforts to address your concern within 45 days of receipt of your complaint.
For any Privacy Shield disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The Federal Trade Commission has investigation and enforcement authority over Growth Strategy’s compliance with the Privacy Shield Framework.
This Privacy Notice was last updated on October, 15, 2022
Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors to their websites. A cookie contains a unique number, which is used to recognize your computer or mobile device when you return to our Website. Cookies can remain on your computer or mobile device for different periods of time. The cookies can be either "persistent" cookies or "session" cookies. Persistent cookies are stored by a web browser and remain valid until a set expiration date. Session cookies only exist while your internet browser is open and are automatically deleted once you close your browser. Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files contained on pages of websites that permit companies to count users who have visited certain webpages on a website and are used for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity). What does Growth Strategy use cookies and web beacons for?
Growth Strategy uses a variety of cookies, web beacons and other tracking technologies for different purposes. Specifically, Growth Strategy uses cookies and web beacons to enhance the experience of our visitors to our Website (for example, by remembering your preferences and letting you navigate between pages efficiently) and to better understand how the Website and Product are used. Cookies may tell us, for example, whether you have visited the Website before or whether you are a new visitor. What types of cookies and web beacons are used by Growth Strategy?
Growth Strategy uses both first-party and third-party cookies and web beacons. First-party cookies and web beacons are cookies and web beacons that are served directly by Growth Strategy to your computer or mobile device. Third-party cookies and web beacons are served by a third-party service provider on behalf of Growth Strategy. Third-party cookies are most commonly used for advertising and analytics purposes. There are four categories of cookies and web beacons used by Growth Strategy. Specifically, Growth Strategy uses essential, performance, functionality and advertising cookies and web beacons. Essential cookies, web beacons and other tracking technologies are necessary for the operation of the Website and Product. These tracking technologies enable you to move around on the Website and use the Website’s features. You may not opt-out of these types of cookies because they are required to operate the Website and Product. Performance cookies, web beacons and other tracking technologies collect information about how you have used the Website and Product. We use performance cookies, web beacons and other tracking technologies to improve the user experience with our Website and Product. Functionality cookies, web beacons and other tracking technologies allow us to remember how you are logged into our Website, when you logged in or out and the actions you have taken while you have been logged into the Website. Advertising cookies, web beacons and other tracking technologies are used by our third-party service providers to deliver advertising to you on other third-party websites as well as help measure the effectiveness of our advertising campaigns. We also use these types of cookies to analyze Website visits and ad conversions from third-party websites. For more information about Facebook’s privacy practices, please see https://www.facebook.com/help/www/213802165366955 Marketing AddThis We use AddThis for their website tools like social sharing buttons. For more information about AddThis’s privacy practices, please see https://www.oracle.com/legal/privacy/addthis-privacy-policy.html Marketing Rollworks We use Rollworks for account based marketing. For more information about Rollworks’s privacy practices, please see https://www.nextroll.com/privacy What are your choices about cookies?
It is your choice as to whether or not to accept cookies. Most browsers allow you to configure the browser settings so that cookies from websites cannot be placed on your computer or mobile device. If you choose not to accept cookies, then you may be able to continue browsing our Website but we may not be able to provide you with certain features. If you want to opt out of advertising or performance cookies, then you may do so by reviewing the privacy policies of the third party service providers who serve the advertising and performance cookies identified above. If you would like further information about cookies and how to manage and delete them, please visit www.allaboutcookies.org or www.youronlinechoices.eu. What are your choices about cookies and interest-based advertisements?
Through the Digital Advertising Alliance and Network Advertising Initiative, several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties. To make choices about internet-based ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations or to learn more about opting out of advertising cookies, please visit the Network Advertising Initiative’s or Digital Advertising Alliance’s consumer opt-out pages, which are located at http://networkadvertising.org/choices/ or www.aboutads.info/choices. For those users located in the European Union, you can visit the European Interactive Digital Advertising Alliance’s user information website a http://www.youronlinechoices.eu/.
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