INTRODUCTION

Krembo LLC. dba Growth-X (collectively “Growth-X” or “Company” or “we” or “us” or “our“) developed and maintains a subscription-based application, chrome extension and service, automating the process of generating and nurturing business leads (“Business Leads”) on behalf of our customers (“Customers”) to leverage and grow our Customer’s businesses, the site is currently available at: https://www.growth-x.com/ (respectively “Platform” and “Website”, and collectively the “Services”).

This privacy policy (“Privacy Policy”) describes our practices of processing data from visitors to the Website as well as our Customers., including what data we may collect from you, how such data may be used, how we safeguard it and how you may exercise your rights related to your Personal Information (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

In the event you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice

For more details regarding the terms and conditions of our Services and Platform, please read our Terms of Use, available at: https://www.growth-x.com/terms. Note that, this Privacy Policy is an integral part of the Terms of Use (collectively the “Agreement”).

TYPES OF INFORMATION WE COLLECT

Depending on your interaction with us (meaning, if you are just browsing our Website, or if you have registered to our Services and opened an account, etc.), we may collect two types of information you, as follows:

  • The first type of information is non-identifiable information which may be made available or gathered through your use of the Services. To clarify, we are not aware of your identity due to such information (“Non-Personal Information”). The Non-Personal Information which is being collected may include usage information and technical information transmitted or automatically collected.
  • The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information may include contact information such as your name, email address, etc., as well as Internet Protocol (“IP”) addresses. You are not required by law to provide us with any information. You can always avoid providing us certain Personal Information; however, you acknowledge that it may prevent you from engaging in certain Services.Information we collect from visitors of our Website
    Type of Information How Do We Use It?
    In the event you contact us for support or other inquiries, by sending us an email or by other means of communications we make available, you will be requested to provide us your full name and email address. We will process this information based on our legitimate interests, and solely for the purpose of responding to your inquiries and provide you with the support or information you have requested. We will retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of future claim, to provide you with support, or to improve our services).
    IP We (directly or by third party service providers as detailed below) may collect our visitors’ IP. We use this for our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Website and Services and the way in which we offer them; (ii) enhancing your experience with the Services; and (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow. Where required under applicable laws, we will request you consent for collection of this type of data through our use of cookies.
    We also collect certain technical data (as detailed above) which relates to your use of the Services. This type of data may include the type of operating system, approximate geo-location, the time and date you access our Website and your actions within our Services.

     

    		 We use this technical data in order to operate and manage our Website.

     

    Information We Collect from Customers

     

    Type of Information How Do We Use It?
    In order to use our Services, you will be required to register and open an account. During the registration flow you will be requested to provide us with certain information such as your first name and email address. Further, during the registration process you will be required to choose a password, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your password. You represent and warrant that you will not provide us with inaccurate, misleading or false information. We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested, and designate your account. We will use your email address in order to send you needed information related to the Services and our business engagement (e.g., to notify you regarding any updates to our Services, send applicable invoices, and additional occasional communications related to the Services) as well as verify your identity.

    In addition, we may process your Personal Information under our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services as well as our newsletter. You are able to unsubscribe from receiving such correspondence from us by clicking on the designated link in the applicable massage that we will send you or by contacting us at: help@growth-x.com

    Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information.
    You may also choose to provide sign in credentials to your social network account (such as LinkedIn or Twitter) in order to provide the Services. Such network account may provide us with access to certain information about you as stored therein (e.g., full name, e-mail and any other information which you made public). We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested, such as to send connection requests or direct messages to Business Leads.
    If you choose to send messages to Business Leads, we will collect the contents of such messages in order to provide you with the service.

     

    		 We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested.
    In the event you wish to purchase a subscription to our service, you will provide our third-party payment processors with certain Personal Information. We do not collect your payment details. We employ third party payment processors and thus, your payment details will be subject to such third-party payment processors privacy practices. Currently we use ChargeBee which its privacy policy is available at:https://www.chargebee.com/privacy/ , stripe which its privacy policy is available at: https://stripe.com/us/privacy/and Bluesnap, which its privacy policy is available at: https://home.bluesnap.com/privacy-policy/

     

     

     Publicly Available Information of Business Leads

    We analyze public websites daily, and collect, gather and analyze information made public, this information includes mostly names, contact information (such as email) and titles of Business Leads. Even though this data was made publicly available by an individual, we respect the privacy and rights of such individual and thus, this Privacy Policy governs also their rights as detailed below.

     

    HOW WE COLLECT INFORMATION

    Depending on the nature of your interaction with the Services, we may collect information as follows:

    • Automatically – we may use Cookies (as elaborated in the Section below) to gather some information automatically.
    • Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a registration process, contact us communications, etc. all as detailed in this Privacy Policy.

    COOKIES POLICY

    We may use our third-party service provider’s software technologies known as “cookies” to collect and store information related to your interactions with the Services. A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker and easier. We also use cookies for internal analytics purposes in order to improve our Services. You can find out more information about cookies at http://www.allaboutcookies.org/.

    In general, there are several types of cookies that may be used on our Website including the following:

    1. Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling user movement around the Website, for the Website and certain features of the Services, as applicable, to function properly, and for security purposes (i.e., used for authentication purposes, prevent fraudulent use, and protect from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the Website or Services may not work.
    2. Analytical, Measurement & Performance Cookies. – These cookies are used to collect information about how our Website and Services are being used, in order to improve them and the way they are offered. These cookies enable us, for example, to assess the number of users who have viewed a certain page as well as their country of origin.
    3. Targeting & Advertising Cookies. – These cookies are set by our third-party service providers. They may be used to build a profile of your interests and show you personalized content and advertisements. They work by uniquely identifying your browser and device.

    The third-party cookies used on our Website are as follows:

    Cookie Purpose Privacy Policy and Opt-Out
    Google Analytics Analytical, Measurement & Performance www.google.com/policies/privacy/partners
    https://policies.google.com/technologies/managing?hl=en
    https://tools.google.com/dlpage/gaoptout

    For additional information regarding our use of Google products, click here.
    Heap Analytics Analytical, Measurement & Performance https://heap.io/privacy
    Intercom Functionality & Operation https://www.intercom.com/terms-and-policies%23privacy
    Facebook Analytical, Measurement & Performance and Targeting & Advertising https://www.facebook.com/policy.php
    https://www.facebook.com/help/search/?q=opt%25252520out%25252520
    HubSpot Analytical, Measurement & Performance and Operation & Functionality https://legal.hubspot.com/privacy-policy?_ga=2.48898406.1547561739.1580054069-1042704558.1573974857

    Cookies Opt-out

    Most browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your device. Each browser is different, but generally users can remove cookies by following directions provided in the browser’s “help” file. Also, you are free to delete any existing cookies at any time. Please note that, if you reject cookies or disable cookies, some features of the Website or Platform may not function properly. For your convenience, see the links below for additional information (click on the applicable type of browser you are using): Google Chrome; FireFox; Internet Explorer; Safari; Edge; Opera

    WITH WHOM DO WE SHARE THE INFORMATION, AND FOR WHAT PURPOSE

    We do not share any Personal Information collected from you with third parties or any of our partners except in the following events: (i) if we have a good faith belief that disclosure of such information is reasonably necessary to comply with any applicable law or legal process; to detect and prevent fraud or other security issues; (ii) in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale); (iii) we may also process your information by our third-party services providers, that may include our affiliated companies. These services providers are instructed to process the data solely as we request and on our behalf.

    DATA RETENTION

    We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

     HOW DO WE SAFEGUARD YOUR INFORMATION

    We take great care in implementing and maintaining the security of Company’s Website, Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information and prevent unauthorized use of any such. We have implemented technical, physical and administrative security measures to protect the Personal Information. In addition, we limit access to your information on our servers. The data collected by us is stored in the AWS data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/. Further, in the event of a data incident, in which we discover your Personal Information may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).

    YOUR RIGHTS, CHOICES AND CONTROLS OF YOUR PERSONAL INFORMATION

    Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Information. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party.

    Please review our User Rights Policy for more information regarding the rights you may have under the relevant data protection and privacy laws in your jurisdiction.

    If you wish to exercise any or all of the above rights, please fill out the Data Subject Request Form (“DSR”) available here and send it to our privacy team at: dpo@growth-x.com

    Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply. Please note that you have the right at any time to contact your local data protection authority.

    DIRECT MARKETING

    We may send our Customers or Business Leads an email or other messages. You can remove your Personal Information from our mailing list and stop receiving promotional communications from us by emailing us at dpo@growth-x.com.  Please note that in the event you are our Service Provider, even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account, without offering you the opportunity to opt out of receiving them unless you terminate and delete your account. If you wish to delete your Account, please contact us at: dpo@growth-x.com. Note that, even if we will delete your account, we will not delete certain information required under applicable law or otherwise, required for the legitimate purposes of our business.

    DATA TRANSFER

    We may store or process your Personal Information in the United States or in other countries. If you visit our Websites or use our Services from locations outside of the United States, please note that any information you provide to us through your use of our Websites or Service may be transferred to and processed in countries other than the country from which you accessed our Websites or Service, including the United States where our central database is operated. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

     CHILDREN’S PRIVACY

    Our Service are not direct or intended for children under 16 years of age. We will not knowingly solicit, collect and store Personal Information directly from children. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. If we later obtain actual knowledge that an individual is considered as a child under applicable law, we will take steps to immediately delete its Personal Information. We request that such individuals do not provide Personal Information through the Services. If you become aware or have any reason to believe that a child has shared any information with us, please contact us at: dpo@growth-x.com.

     AMENDMENTS

    We reserve the right to periodically amend or revise this Privacy Policy at our sole discretion; such changes will be effective immediately upon the display of the revised Privacy Policy. The last revision date will be reflected in the “Last Modified” heading. Your continued use of our Services following the amendments constitutes your acknowledgement, and where applicable, your consent, of such amendments to the Privacy Policy. In the event of a material change we will make best efforts to display applicable notification in our Website or if applicable, notify you via email or through your Account.

     GOOGLE CHROME WEB STORE POLICES

    Our browser extension, available to our Customers as part of our Platform, will adhere to the Chrome Web Store User Data Policy, including the Limited Use requirements.

     CONTACT US

    If you have any questions or comments about this Policy, or any concerns with respect to how your privacy any information are handled, please contact us at:

    Krembo, LLC.

    3250 NE 1st Ave Unit 305, Miami, FL 33137

    You can also contact us via email at: dpo@growth-x.com

    DATA PROTECTION OFFICER:

    If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@growth-x.com. lease include your name, address and email address in any correspondence so that we can respond to your inquiry or request.