Privacy Policy

GrowthCircle ("we", "us", or "our") operates the website growthcircle.app and related browser extensions (collectively, the "Service"). This Privacy Policy explains how we collect, use, store, and protect your personal data when you use the Service.

GrowthCircle acts as the data controller for the personal data described in this policy. We are committed to protecting your privacy in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other applicable data protection laws.

By using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please do not use the Service.

The data controller responsible for your personal data is:

If you have any questions about how we process your personal data, or if you wish to exercise your data protection rights, please contact us at the email address above.

We collect and process the following categories of personal data:

We process your personal data for the following purposes:

• To respond to your inquiries and contact requests.
• To provide, maintain, and improve the Service, including the browser extension.
• To analyze website usage and optimize the user experience.
• To detect and prevent fraud, abuse, and security incidents.
• To comply with legal obligations.
• To enforce our terms of service and protect our rights.

We use the following types of cookies:

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

• Contact form submissions: retained for a maximum of 2 years from the date of submission, then permanently deleted.
• Analytics data: retained for a maximum of 14 months, in accordance with Google Analytics data retention settings.
• Browser extension usage data: retained for as long as your account is active, and deleted within 90 days after account termination.
• Technical logs (server logs, security logs): retained for a maximum of 90 days.

When data is no longer needed, it is securely deleted or anonymized so that it can no longer be linked to you.

We share your personal data with the following third-party service providers (sub-processors) who process data on our behalf:

All sub-processors are bound by data processing agreements that require them to process your data only in accordance with our instructions and applicable data protection law. We regularly review the compliance and security practices of our sub-processors.

Some of our sub-processors are located outside the European Economic Area (EEA). Where personal data is transferred to a country outside the EEA that has not been deemed to provide an adequate level of data protection by the European Commission, we ensure that appropriate safeguards are in place, such as:

• EU Standard Contractual Clauses (SCCs) adopted by the European Commission.
• The EU-U.S. Data Privacy Framework, where the recipient is certified.

You may request a copy of the applicable safeguards by contacting us at privacy@growthcircle.app.

Under the GDPR, you have the following rights regarding your personal data:

• Right of access (Article 15) You have the right to obtain confirmation of whether we process your personal data and to receive a copy of that data.
• Right to rectification (Article 16) You have the right to request the correction of inaccurate personal data and the completion of incomplete personal data.
• Right to erasure (Article 17) You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or when you withdraw your consent.
• Right to restriction (Article 18) You have the right to request that we restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of your data.
• Right to data portability (Article 20) You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.
• Right to object (Article 21) You have the right to object to the processing of your personal data based on our legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds.
• Right to withdraw consent Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at privacy@growthcircle.app. We will respond to your request within 30 days. If we need additional time, we will inform you of the reason and the expected timeline.

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS 1.2 or higher.
• Encryption of data at rest.
• Access controls and role-based permissions for personnel.
• Regular security reviews and vulnerability assessments.
• Passkey-only authentication (WebAuthn) with no passwords stored.

The Service is not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If you believe that we have collected personal data from a child under 16, please contact us at privacy@growthcircle.app and we will take steps to delete that data promptly.

If you believe that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or through a notice on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.