GrowthLab Privacy Policy – Last updated September 2023

This Privacy Policy (“Privacy Policy”) explains how GrowthLab Financial Services, Inc. (“GrowthLab” or “we”, “us”, “our”) and its subsidiaries and affiliated companies collect, use and store personal information (“PI”) when an individual (“you” or “your”) interacts with our website www.growthlabfinancial.com (the “Website”) and/or GrowthLab’s online Engagement Tools, including GrowthLab's contact forms (the “Engagement Tools”). 

Your Consent

By using the Website or the Engagement Tools, you consent to our use of your PI as described in this Privacy Policy. As we implement new technology and introduce new services, we will update our Privacy Policy, so we encourage you to review it often. We reserve the right to change our Privacy Policy at any time without advance notice. Should any new privacy policy go into effect, we will post it on the Website, and the policy will apply to all PI collected. You can withdraw your consent at any time as specified in the “Your Privacy Rights” section below. Any data that relates to an identified or identifiable individual or that is linked or linkable to an individual is “personal data,” such as data that directly identifies you (like your name or email address) and data that can reasonably be used to identify you (like your IP address). Aggregated data is considered non-personal data for the purposes of this Privacy Policy.

Personal Information GrowthLab Collects from You

When you use the Website or the Engagement Tools, we allow you to provide PI. We collect data from you directly through your use of the Website and Engagement Tools.

Personal information is data that can be used to identify or contact an individual person.  GrowthLab has collected the following categories of personal information from its users in the last twelve (12) months:

Categories

Identifiers

Name, email address, phone number, IP address, or other similar identifiers.

Commercial information

Records of products purchased or considered.

Internet or other electronic network activity information

Browsing history, search history, and information regarding a user’s interaction with the Website. 

Sensitive information

Geolocation.

If you do not wish us to collect this information, do not supply it to us.

How We Use Your Personal Information

We use the PI we collect from you for improving the Website and Engagement Tools, to send you information you have requested, to provide you with the requested services or for our own marketing and research purposes. If you have provided PI to GrowthLab through our Engagement Tools, we send your PI to the relevant members of our internal team. We will not use or share your information with anyone except as described in this Privacy Policy. We do not sell any PI to any third party.

GrowthLab Use of Cookies

Cookies are pieces of information that a website transfers to an individual’s hard drive for record-keeping purposes. Most web browsers automatically accept cookies. Typically, however, you may configure your browser to refuse all cookies or notify you when a cookie is being sent. The only cookies used on the Website are those used by third party libraries that have been used to build the website or 3rd party data tools that use cookies to collect data on site visitors. 

Third Party Service Providers

We may employ third-party companies and individuals to assist us with our Website and Engagement Tools from time to time. These third parties may be provided access to your PI in order to render services to us. Over the last twelve (12) months, we have disclosed for business purposes the following categories of PI to third parties: email, first name, last name, and phone number.  Pursuant to California’s “Shine the Light Act,” California residents are permitted to request information about the manner in which we share certain categories of PI with third parties for their marketing use. Please send an email to contact@growthlabfinancial.com to request a copy of our disclosure pursuant to California law.  While we will require third parties to follow applicable laws, and will not authorize them to use this information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties. However, if you opt out of internet-based advertising in the “Your Privacy Rights” section, we will not disclose your information to any third parties for this purpose.

Others

It may be necessary for GrowthLab to disclose your personal information by law, legal process, litigation, and/or requests from public and governmental authorities. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect the Website, Engagement Tools or users.  This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Security

GrowthLab uses industry standard procedures to store information, including by storing information on secure computers located in locked data centers. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure PI, it is not guaranteed, and you cannot expect that the Website or Engagement Tools will be immune from information security risks. GrowthLab retains your personal information for as long as necessary to provide the applicable Engagement Tools.

Links to Other Sites

Our Website may contain links to other sites. These sites may have their own privacy statements or policies in place, which we recommend you review if you visit any linked sites. We are not responsible for the content of linked sites or any use of the sites.

Your Privacy Rights



When you submit PI that contains your phone number and/or email through the Website or our Engagement Tools, you are providing us with your express written consent to receive communications from us at that phone number and/or email you provided to us. You can make choices about our collection and use of your information. You can control your personal data that GrowthLab obtains, and exercise your data protection rights, by contacting GrowthLab or using various tools we provide.

For example, you can:

• Use the “unsubscribe” links contained in our email messages to stop receiving product or promotional offers from us via email. 
• Revoke your consent by replying "STOP" to any text message you receive from us.
• Disable push notifications sent to your mobile device to communicate with the Website or Engagement Tools via the applicable settings at your discretion.
• Prevent the Website or Engagement Tools from obtaining your location by disabling location services on your device. However, doing so means you may not be able to use certain features of the Website or Engagement Tools.
• Tell us to correct your personal information that we use. If you wish to exercise this right, please contact us at contact@growthlabfinancial.com.
• Direct us to limit the use of your Sensitive Personal Information solely in order to provide you products and services. If you wish to exercise this right, please do so at contact@growthlabfinancial.com.

Not all personal information processed by GrowthLab can be accessed or controlled via the tools above. If you want to access or control personal data processed by GrowthLab that is not available via the tools above, you can always contact GrowthLab at contact@growthlabfinancial.com.

California

If you are a California resident, the California Consumer Protection Act (“CCPA”) provides you with specific rights regarding your PI. 

You have the right to:

• Request that GrowthLab disclose to you the categories and specific pieces of PI we have collected and/or shared.
• Correct and delete any PI about you which GrowthLab has collected from you.
• Request that GrowthLab also disclose the following to you:

1. The sources from which your PI is collected.
2. The business or commercial purpose for collecting or sharing your PI.
3. The categories of third parties with whom GrowthLab shares PI.

• Direct GrowthLab to limit the use of your sensitive personal information.

To exercise the rights set forth above, you may submit a request to us by emailing us at contact@growthlabfinancial.com. If GrowthLab deletes your personal information, GrowthLab will both render certain personal information about you permanently unrecoverable and also de-identify certain personal information.

If you choose to exercise your privacy rights, you have the right not to receive discriminatory treatment or a lesser degree of service from us.

Children’s Privacy

The Website and Engagement Tools are intended only for use by adults and not expected to be used or accessed by children. GrowthLab shall not seek to obtain, store, distribute or use any information regarding children. If we discover that a child provided us with PI, we will immediately delete said PI from our servers. If you are a parent or guardian and you are aware that your child has provided us with PI, please contact us at contact@growthlabfinancial.com so we can take the necessary steps to delete your child’s PI.

Changes to This Privacy Policy

We may occasionally update this Privacy Policy. When we do update this Privacy Policy, we will also revise the “Last Updated” date at the top of the Privacy Policy. Please review this Privacy Policy periodically to stay informed about how we are protecting the Personal Information we collect. If you continue to use the Website and the Engagement Tools after we post an update to this Privacy Policy, you are indicating your acceptance of the updated Privacy Policy.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at contact@growthlabfinancial.com.