Privacy Policy on Personal Data Processing

1. Basic Terms & Operator Information

This Privacy Policy governs the processing and protection of personal data collected through the website Growlex.io, the Growlex Lens AI diagnostic platform, Growlex Radar, and associated services operated by Growlex.io ("Operator", "Company", "we", "our", or "us").

By accessing our website, using our diagnostic calculators, requesting growth audits, or entering into commercial engagements with us, you ("User", "Client", or "Data Subject") acknowledge that you have read, understood, and agreed to the practices described in this Policy.

2. Basic Concepts Used in This Policy

• Personal Data: Any information relating directly or indirectly to an identified or identifiable natural person.
• Processing of Personal Data: Any action (operation) or sequence of actions performed with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
• Automated Processing: Processing of personal data using computer technology and algorithmic automation.
• Diagnostic Data: Quantitative parameters submitted by Users (e.g. monthly ad spend, average order value, target conversion rates, advertising domain) for running real-time growth simulations and audits.
• Confidential Client Information: Commercial advertising metrics, campaign configurations, creative deconstructions, and financial performance figures shared under an agency agreement or during an audit.

3. Personal Data Collected

We only collect data strictly necessary to deliver high-quality growth engineering services, run automated audits, and respond to strategic inquiries. Depending on your interactions with us, we may collect:

• Contact Details: Your full name, work email address, telephone number (including country dialing code), and company name or brand domain.
• Business & Campaign Parameters: Monthly ad spend range (e.g. Under $10k, $10k–$50k, $50k–$100k, $100k+), primary marketing challenges, and diagnostic queries provided via forms or file attachments.
• Automated Technical Identifiers: IP address, browser type and version, language preferences, operating system, timestamp of access, referral URLs, and clickstream data.
• Attribution & Analytics Tags: Google Analytics ClientID, UTM campaign parameters (utm_source, utm_campaign), Google Click Identifier (gclid), and Meta Click Identifier (fbclid) for marketing attribution and bot-prevention.

4. Purposes and Legal Bases for Processing

We process personal data on lawful grounds, including the necessity of performing a contract or pre-contractual steps at your request, compliance with legal obligations, and our legitimate commercial interests in operating a secure and reliable platform:

5. Strict Client Data Isolation & Confidentiality

CANONICAL POLICY: Growlex.io enforces absolute data partition between client accounts. We operate under strict zero-cross-contamination protocols:

• We never disclose, blend, or reuse financial performance, CAC figures, conversion rates, or internal ad accounts of one client for another client’s reports.
• All audit workspaces in Growlex Lens AI and Growlex Radar are generated dynamically and exclusively based on the user's explicit session inputs.
• Client advertising data is never sold, leased, or licensed to data brokers or advertising exchanges.

6. Third-Party Service Providers & Subprocessors

To deliver reliable hosting, real-time analytics, and secure communications, we engage trusted third-party service providers who comply with stringent security standards:

• Cloudflare Inc.: Web application firewall, edge caching, and global serverless hosting (Cloudflare Pages & Workers).
• Google Analytics 4 & Google Tag Manager: Website traffic measurement, engagement analysis, and conversion attribution (configured with IP masking).
• Cal.com Inc.: Appointment scheduling and calendar synchronization for strategic consultations.
• Telegram Bot API: Instant secure notification dispatch for internal team notification upon voluntary lead submission.

7. Google API Services & Advertising Data Compliance

Where Growlex.io accesses Google user data, advertising statistics, or Google Ads Manager APIs on behalf of a Client, our use and transfer to any other app of information received from Google APIs adheres strictly to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically, Google user data is used solely to calculate campaign efficiency, identify ad waste, and optimize performance for the authorized account. We do not use Google user data to serve advertisements, nor do we allow humans to read this data unless explicitly authorized by the Client for troubleshooting.

8. Data Security and Safeguards

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

• End-to-end Transport Layer Security (TLS 1.3) encryption for all web communications.
• Strict role-based access control and principle of least privilege for internal infrastructure.
• Encrypted credential vaults and automated deletion of temporary diagnostic session files.

9. Data Retention & User Rights

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or to satisfy legal, accounting, or reporting requirements.

Under applicable data protection laws (including GDPR and CCPA/CPRA), you have the right to:

• Access & Portability: Request confirmation of processing and obtain a copy of your stored personal data.
• Rectification: Request correction of inaccurate or incomplete personal information.
• Erasure ("Right to be Forgotten"): Request the complete deletion of your personal data from our systems.
• Withdrawal of Consent: Withdraw previously granted consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please email us directly at hello@growlex.io. We respond to all verified requests within thirty (30) days without charge.

10. Cookies and Tracking Technologies

Growlex.io uses cookies and similar browser storage technologies to maintain security, remember user preferences, and analyze aggregated traffic. You can configure your browser settings to reject cookies or alert you when cookies are placed. Note that disabling certain essential cookies may affect the interactive functionality of the diagnostic tools.

11. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy as our services evolve and applicable regulations require. Any updates will be posted directly on this page with an updated revision date. Material changes will be prominently announced on our website or communicated directly to registered clients.