Privacy Policy



Last Updated: January 15, 2021
GrowthCode a d/b/a company of Capital Strategies, LLC. (“GrowthCode”, “we”, “us”, “our”) is committed to protecting your privacy. GrowthCode operates a number of websites (each a “Site”) and provides services available through the Sites to access the API, to access data and services, to prevent fraud, to update contact information, or to improve contact information (collectively, the “Services”). This Privacy Policy describes how we collect, use, process, and disclose your information, including Personal Data (as defined below), in conjunction with your access to and use of our Services, and it applies to all of the Services offered by GrowthCode and its affiliates. “Users” as defined in this Privacy Policy includes any user of our Services including individual End Users, organizational Clients, and Developers.Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use located at GrowthCode Terms or your executed Client Agreement. PERSONAL DATA WE COLLECT“Personal Data” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. The following are categories (with non-exhaustive examples) of Personal Data we may collect about you and for each category the purpose for which it may be used:CategoriesExamplesProcessing Purpose1.1 Personal Data Related to Your Account as a User.1.1.a. Contact Information full name, organization, phone number, email address, password token, photos, type of business, business use case, general location, or other similar identifiersProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.1.b. Payment Informationfull name, credit card, billing addressProvide, Maintain, and Support Services1.1.c. Product Related Communicationemail address, phone, full name, audio, additional information you provideProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and Marketing1.1.d Usage Datafull name, email address, phone number, URLs, social handles, physical address, online identifiers, or other similar identifiersProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.1.e. Connected 3rd Party Services/Integrationsname, email address, passwordProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.2 Personal Data Provided or Generated When Using Our Services1.2.a. Contact Datafull name, email address, phone number, URLs, social handles, profile photo, physical address, online identifiers, or other information associated with your accountProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.3 Website (any website information not provided below, such as online identifiers is aggregated or de identified using 3rd party providers)1.3.a. Forms/Chatsfull name, email, job title, phone, organization, industry, general location, additional information you provideProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.3.b. AnalyticsInformation on an individual’s interaction with our website or advertisement, browsing historyProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCreation of Deidentified, Aggregate, or Anonymous Information1.3.c Ad NetworksInformation about an individual’s experiences and interactions from our partner ad networksProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCreation of Deidentified, Aggregate, or Anonymous Information1.4 Personal Data we Receive from Third Parties or Affiliates for Use in our Services.1.4.a Open Dataage gender, social URLs, full name, company name, company bio, general location, education, job titleProvide, Maintain, and Support ServicesImprove, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.4.b Data Providersage, gender, organization, job title, business email, interests, social affinities, social URLs, payment type, retail shopper, marital status.Provide, Maintain, and Support Services.Improve, Personalize, and Develop the ServicesProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.5 Personal Data we Get from Third Party Services for Use in Sales/Marketing1.5.a Prospect Listsfull name, company name, emailProvide, Personalize, Measure, and Improve our Advertising and MarketingCombine Contacts for Identity Resolution & Verification ServiceCombine Contacts for Contact Enrichment ServicesCreation of Deidentified, Aggregate, or Anonymous Information1.6 Personal Data You Provide Us in Claim Your Data1.6.a. Authorization Datafull name, email, physical address, phone number, access codeProvide, Maintain, and Support ServicesWe collect Personal Data, as described below.Sources of Personal Data. We obtain the categories of Personal Data listed above on or through our Services from the following categories of sources:1.1 Personal Data Related to Your Account as a User. GrowthCode collects Personal Data when you voluntarily submit it to us. For example, we may collect or receive Personal Data from Users when a User creates a GrowthCode Account; edits Registration Information; signs up to receive promotional communications; uses or accesses features available through the Services or GrowthCode Data; participates in one of our promotional sweepstakes, contests, or surveys; posts a review; submits a request to our customer service team; interacts with our social media pages; or otherwise interacts with us or other Users through the Services.Contact Information. When you sign up for a GrowthCode Account, we may require certain information such as your full name, organization, phone number, email address(s) and password token. You may optionally choose to sign into GrowthCode using a third party (e.g., your Google login). If you choose to do this, you will be asked whether you agree to the third party providing certain information to GrowthCode, such as your name, email address, profile photo, and other information associated with your Account.Payment Information. Some of our Services require payment. We may use third party payment service providers such as Stripe to collect all the information necessary to complete the transaction. We never share your billing and payment information except with these payment service providers.Product Related Communication. If you contact or interact with us (for example via support, feedback, surveys, forum, chat, promotions) we may collect information such as your name, phone number, email address, as well as any other content that you provide. We also may create event logs to diagnose Service or product related issues, and capture information relating to any support issues. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives and analyze any feedback provided through voluntary customer surveys.Usage Data. Personal Data may be collected through your experiences and interactions within the developer dashboard and through the use of the GrowthCode API. For example, User may provide an email within our search feature to see additional contact elements that may be returned with that email.Connected Third-Party Services/Integrations. Many GrowthCode Services allow you to connect with external systems or databases. Examples include but are not limited to: (i) communication platforms such as email providers, video conferencing systems, calendar applications, and social networks, and (ii) sales, marketing, customer service, and media platforms. Connections to such services generally require you to sign into those services.1.2 Personal Data Provided or Generated When Using Our Services. GrowthCode provides a variety of Services that may collect Personal Data such as submitting Contacts through GrowthCode’s API (both lookup and search), upload of lists/files of Contacts for processing, or with the transfer of Contacts from certain third-party integrations. We also provide a variety of Services that enable you to effectively manage contact information that you provide to us as part of those Services (your “Contacts”, also referred to as “End User Contact Data” in our Terms of Use). Contacts typically contain information on individuals (or organizations) including names, email addresses, phone numbers, URLs, social handles, online identifiers, and physical addresses. Your Contacts may also contain additional information on individuals such as organizational affiliations, job titles, birthdays, key dates, age, gender, general location, relationships, skills, interests, preferences, notes, photos, tags and other categorizations.1.3 Website. We may collect information on User interacts with our Site, promotions, or advertisements. Third parties may also collect Personal Data as described below.Forms/Chats. If you contact or interact with us on the site via chat or site forms, we may collect information such as your name, phone number, email address, as well as any other content that you provide.Analytics. We may collect and allow third parties to collect information about how you use and interact with our Site and Services. Examples of third-party providers of analytics and similar services we currently use include:Google Analytics. Used to track site statistics and user demographics, interests and behavior on websites.Ad Networks. We may receive Personal Data about you and your activities whether as part of or outside our Services through partnerships, or about your experiences and interactions from our partner ad networks.1.4 Personal Data we Receive from Third Parties or Affiliates for Use in our Services. We may receive Personal Data that others provide about you when they use the Services (through Contacts provided to us as described above), or obtain information from other sources, including but not limited to public or licensed APIs (“Open Data”), third-party data partners and affiliates (Contacts+), and data research. We do not control, supervise, or respond for how the third parties process your Personal Data.Open Data. Open Data includes information that is in the public domain or has been declared public knowledge by someone with the authority to do so and can freely be given to anyone. Personal Data may be collected through our open data sources. We openly share this data, while abiding by relevant terms and conditions.Data Providers. We may collect Personal Data from reliable marketing/data providers gathered from sources including but not limited to public records, warranty information, surveys, opt-in subscriptions, public filings, public directories, and other publicly available sources.1.5 Personal Data we Receive from Third Party Services for Use in Sales/Marketing. We may receive Personal Data from other third-party sources, third-party data partners and affiliates, and data research.Prospects Lists. In an effort to personalize and provide information on GrowthCode products or Services that may be of interest to you, we may collect Personal Data from third-party sources such as name, email, company name, job titles, and more.1.6 Personal Data You Provide Us in Claim Your DataAuthorization Data. When you want to verify your Personal Data via our Services, we may require you to provide certain information such as your general location, phone number, and email address(s) prior to granting access to your Personal Data for verification purposes only.To the extent permitted by applicable law, Personal Data does not include:Publicly Available Data – Publicly available information from government records.Deidentified, Aggregate, or Anonymous Information – “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which GrowthCode has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device. “Anonymous Information” means information that is not associated with or linked to an individual and does not, by itself, permit the identification of an individual.Excluded Information – Certain laws require separate privacy notices or are exempt from general personal information privacy policy disclosure requirements. Such laws include health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or clinical trial data; the Gramm-Leach-Bliley Act (GLBA); Fair Credit Reporting Act (FCRA); and the Driver’s Privacy Protection Act of 1994.HOW WE USE PERSONAL DATAWe primarily use, store, and process Personal Data to provide, understand, improve, and develop our Services, create and maintain a trusted and safer environment, and comply with our legal obligations. We also use Personal Data for the following purposes:2.1 Provide, Maintain, and Support the ServicesUsing Personal Data we collect, we are able to deliver the Services to you and honor our Terms of Use. We need to use Personal Data you provide to facilitate the creation of and secure your Account on our network, identify you as a User in our system, provide improved administration and quality of experience of our Site and Services, send email, call, or send SMS text messages to you to verify ownership of the email address or phone number provided when your Account was created, send you Service, support or maintenance messages, updates, security alerts, and Account notifications. Your Personal Data may also be used for the detection and prevention of fraud, spam, abuse, and other harmful activity, and for any purpose you authorize at the time of collection.Additionally, to provide you technical support, we may need to review your Account and the contents of your Account to identify, research, troubleshoot, and resolve any issues that you report to us or that we otherwise become aware of.2.2 Improve, Personalize, and Develop ServicesWe use Personal Data we collect to improve and personalize the Services and to develop new ones. For example, we use Personal Data to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.2.3 Provide, Personalize, Measure, and Improve our Advertising and MarketingWe may process Personal Data for marketing purposes including offering you products or Services that may be of interest to you (such as information about GrowthCode Services or partner campaigns and other third party services). We may also administer referral programs, rewards, surveys, sweepstakes, contests, newsletters, or other promotional activities or events sponsored or managed by GrowthCode or its third party partners. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your GrowthCode Account.2.4 Combine Contacts for Identity Resolution & Verification ServicesCertain categories of Personal Data may be combined to build more complete contact records of individuals (“Completed Contact Data”). Completed Contact Data reside in the GrowthCode Database and may be processed for the following purposes in connection with providing Identity Resolution and Verification Services:Grouping contacts and contact elements into unique individuals to create Completed Contact Data.Generating and returning a unique identifier for an individual and associated Completed Contact DataLinking (or “matching”) input contact records to Completed Contact Data for purposes of identifying an individual, searching for an individual, and/or linking to other contact records (such as those submitted by 3rd-parties) associated with the same individual.Deduplicating a set of input contact records based on unique individualsInferring linkages between and/or deduplicating existing Completed Contact DataVerifying the accuracy and recency of contact elements contained within input contact recordsFor example, someone may search or lookup a Contact by name and email address. GrowthCode connects the name and email with a Completed Contact Data within the GrowthCode Database for one of the reasons above. No additional Contact Data beyond the unique identifier are returned to the User submitting the search.2.5 Combine Contacts for Contact Enrichment ServicesCertain categories of Personal Data may be made available to our customers and partners in connection with providing Enrichment Services.Contact enrichment is often combined with Identity Resolution so that, for example, a User is able to match a Contact that they possess to our Completed Contact Data, and receive back a subset of the contact information from the relevant Completed Contact Data for that individual and/or other contacts records linked to the same individual. For example, we may return an individual’s name to support features such as caller ID. Other examples of data that may be returned by our Enrichment Services include: social handles, hashed identifiers, basic demographic information, profile photos, consumer interests, and professional information such as business emails, organizational affiliation and job title. See our developer docs for a list of currently available enrichment data.2.6 Creation of Deidentified, Aggregate, or Anonymous InformationWe may create Deidentified Information, Aggregate Information, or Anonymous Information records from Personal Data by excluding certain private data in a manner that makes the data not personally identifiable. We use this Deidentified Information, Aggregate Information, or Anonymous Information to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. GrowthCode reserves the right to use Deidentified Information, Aggregate Information, and Anonymous Information for any purpose, including providing Services to our Users, and disclose Deidentified Information, Aggregate Information, and Anonymous Information to third parties in its sole discretion, including (but not limited to) regulatory compliance, industry and market analysis, demographic profiling, modeling, marketing and advertising, and other business purposes.HOW PERSONAL DATA IS SHARED3.1 When You Consent, Agree or Direct Us to ShareYou may authorize us to disclose your Personal Data to others, such as when you connect a third party application or website to access your GrowthCode Account, when you participate in promotional activities conducted by GrowthCode partners or third parties or when you exercise consent as requested in the use of our Services.3.2 Sharing Between UsersTo provide our Services, for commercially purposes, specifically our Identity Resolution and Verification Services and Enrichment Services, we may need to share certain Personal Data with other Users of our Services, as it is necessary for the adequate performance of the contract between you and us and for performance of certain features of our Services based on our legitimate interest. Examples include, but are not limited to, sharing information for the fulfillment of our Terms of Use or Master Services Agreement or through our  Services for the purposes of improving the Services for both you and other End Users and Developers.3.3 Sharing Between Business PartnersWe may provide Personal Data for commercial purposes to business partners and third parties that we believe may offer products or services of interest to you. We screen all such third parties that receive such Personal Data and review the intended use of the information before providing any information to them. These parties may include such companies as software and hardware providers, consumer product providers, marketing coops, information providers, digital marketers, ad agencies, web publishers, data management platforms, and social media networks3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of Yours or Our RightsRegardless of any choices you make regarding your Personal Data (as described below), GrowthCode may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with applicable laws, including laws outside your country of residence; (c) to respond to requests from public and government authorities (including authorities outside your country of residence) or to respond to subpoenas or warrants served on GrowthCode; (d) to protect or defend the rights or property of GrowthCode or that of you or other End Users or Developers; or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use. In addition, under certain applicable laws, individuals may have the right to require that we disclose to them their Personal Data that we store in the GrowthCode Database. GrowthCode will make such disclosures required by law, but we will not disclose you as the source of that information unless required by law.3.5 Service ProvidersGrowthCode uses a variety of third party service providers to help us provide our Services. These Service providers may be located anywhere worldwide in countries outside your country of residence. In particular, currently use service providers based in Europe, India, Asia Pacific and North and South America.In order to facilitate payments for Services we provide, certain information as described above may be shared with the relevant payments service providers. This payment related data sharing is necessary for the performance of the contract between you and us.These service providers may have limited access to your information as necessary to perform these services on our behalf, and are contractually bound to protect and to use your Personal Data only for the purposes for which it was disclosed and consistent with this Privacy Policy.GrowthCode may need to share your Personal Data in order to deliver the Services to you and honor our Terms of Use.3.6 Corporate AffiliatesTo enable or support us in providing the Services, we may share your  Personal Data, in compliance with local data privacy laws, within our corporate family of companies that are related by common ownership or control.Sharing with GrowthCode, Inc. Even if your country of residence is not the United States, your Personal Data may be shared with GrowthCode, Inc. which provides the technical infrastructure for the Services, product development and maintenance, customer support, trust and safety and other business operation services to other GrowthCode affiliates and subsidiaries.Sharing with GrowthCode Affiliates and Subsidiaries. Your Personal Data may be shared with our wholly owned affiliates and subsidiaries. Personal Data shared in these circumstances may include Contact information.3.7 Social Media PlatformsWhere permissible according to applicable law we may use certain derivative Personal Data about you, such as a cryptographic hash of a personal email and share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our Sites or otherwise promote our Services. The social media platforms with which we may share your Personal Data are not controlled or supervised by GrowthCode. Therefore, any questions regarding how your social media platform processes your Personal Data should be directed to such platform.Please note that you may, at any time ask GrowthCode to cease processing your Personal Data for these direct marketing purposes by sending an email to: opt-out@GrowthCode.io.3.8 Business TransfersIf GrowthCode undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Data, in connection with such transaction, or in preparation for or contemplation of such transaction (e.g., due diligence).PERSONAL DATA RETENTIONWe generally retain your Personal Data for as long as is necessary for the performance of the Services to you and our other Users and to comply with our legal obligations. This includes information that you have made available to the GrowthCode Database for the purposes of improving the Services for both you and other Users of our Services.You may request that we delete your Personal Data and close your GrowthCode Account or you can delete your End User Contact Data and close your Account on your own. Please note that if you request the deletion of your Personal Data or if you delete your Personal Data:We may retain some of your information as necessary for fraud detection and prevention and enhancing safety. For example, if we suspend a GrowthCode Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new GrowthCode Account in the future.We may retain and use your information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing obligations.Information you have shared with other systems (e.g., Google) may continue to exist in those systems, and in some cases be publicly visible.Some copies of your information (e.g., log records) may remain in the GrowthCode Database, but are disassociated from personal identifiers.Because we maintain backup to protect our Services from accidental or malicious loss and destruction, residual copies of your information will be included in backups and may not be removed from our backup systems.THIRD PARTY WEBSITESWhen you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect personal information from you. We have no control over, do not review, and cannot be responsible for, these outside websites, or the manner in which they collect, use, and handle information or content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of personal information after you click on links to such outside websites.PERSONAL DATA PROTECTION6.1 SecurityWe have implemented reasonable and appropriate administrative, technical, organizational, and physical measures to help protect your Personal Data. Some of the safeguards we use to protect your Personal Data are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Account ID have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the “Contact Us” Section below.6.2. Our International Operations and Data TransfersTo bring you our Services, we operate globally. We may transfer, store, and process your Personal Data within our family of companies or with service providers based in Europe, India, Asia Pacific, and North and South America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the European Economic Area (the “EEA”) may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy.6.3 EU-US and Swiss-US Privacy ShieldGrowthCode Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework 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 Switzerland to the United States, respectively. GrowthCode has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, GrowthCode is subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at: GrowthCode, Inc., Legal Department, 1624 Market St Ste 226 PMB 45057 Denver, Colorado 80202-2523 or via email privacy@GrowthCode.io. If we are not able to resolve your concern, you may also contact our designated Privacy Shield independent dispute resolution provider, BBB EU Privacy Shield. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.YOUR RIGHTS7.1 Email ChoicesWe offer you choices regarding the collection, use, and sharing of your Personal Data. If you are a User of our Services, we may periodically send you free newsletters and emails that promote our Site or Services as well as third party products or services we think you may be interested in. When you receive such promotional newsletters or communications from us, you may indicate a preference to stop receiving them from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.7.2 Access, Correction, and DeletionGrowthCode allows any individual, including the End Users of our Services, to access, modify, and set permissions with respect to Personal Data that it holds about them. You and any individual may access and make corrections and choices about their Personal Data by choosing “Own Your Personal Data” on the GrowthCode Site.Please note however that, if you request that we delete your Personal Data, we will not do so to protect your rights and freedoms because, if we do, another User may later upload your contact information and we will not have a record that you requested that your contact information be deleted. Were permitted or required by applicable law, instead of deleting your End User Contact Data from the GrowthCode Database, we will retain it but flag it, restrict any further processing and not use or share it with any third parties. Finally, GrowthCode provides you with the ability to export your Personal Data, End User Contact Data, or Completed Contact Data from some of our Services at any time using industry standard formats.Further information for data subjects can be found at Privacy Notice for Data Subjects.7.3 Behavioral-Based AdvertisingWe participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Site so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Site, or on other websites. If you wish to limit third parties’ collection of cookie information about your use of our Site, you can opt-out of such at the Digital Advertising Alliance or Network Advertising Initiative in the U.S., the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. Mobile app users may opt out of receiving behavioral-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL-BASED ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE SITE. IT WILL, HOWEVER, EXCLUDE YOU FROM BEHAVIORAL-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.7.4 Do-Not-TrackSome web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.CALIFORNIA PRIVACY RIGHTS8.1 Notice of Disclosure for California Residents. GrowthCode must disclose whether the following categories of Personal Data are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have Personal Data in that category about you. In the preceding twelve months, we have disclosed the following categories of Personal Data in the manner described.CategoryPersonal Data is Disclosed for a Business PurposePersonal Data is Disclosed for Valuable Consideration1.1.a. Contact InformationYesNo1.1.b. Payment InformationYesNo1.1.c. Product Related CommunicationYesNo1.1.d Usage DataYesNo1.1.e. Connected 3rd Party Services/IntegrationsYesNo1.2.a. Contact DataYesYes1.3.a. Forms/ChatsYesNo1.3.b. AnalyticsYesNo1.3.c Ad NetworksYesYes1.4.a Open DataYesYes1.4.b Data ProvidersYesYes1.5.a Prospect ListsYesNo1.6.a.Authorization DataYesNo8.2 Right to Opt Out of Disclosure of Personal Data for Valuable Consideration. Residents of California have the right to direct us to not sell Personal Data. To exercise the right to opt-out, you (or your authorized agent) may submit a request to us by visiting the following link: “Own Your Personal Data”. Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize Personal Data sales. However, you may change your mind and opt back into Personal Data sales at any time by visiting the following webpage link: “Own Your Personal Data”. You do not need to create an Account with us to exercise your opt-out rights. We will only use Personal Data provided in an opt-out request to review and comply with the request.8.3 Notice of Disclosure for Direct Marketing. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. Alternately, such businesses may have in place a policy not to disclose a customer’s personal information to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. You can opt-out of our sharing of your Personal Data with third parties for their direct marketing purposes by clicking on the “Own Your Personal Data” in that section of our Privacy Policy and choosing to “Do Not Share”. To find out more about your opt-out rights, please contact us at the address listed in Section 12 of the Privacy Policy. Please note that under California law businesses are only required to respond to a customer making such a request once during any calendar year.EUROPEAN PRIVACY RIGHTSIn the use of our Services we mainly act as data processor and, in some cases, we may act as data controller when we determine the purposes and means of the processing of Personal Data.EEA residents may exercise any of the rights described in this Section by using the applicable functionality in our Services or by contacting us directly. If you reside outside of the European Union, you may have similar rights under your local laws. Please note that we may ask you to verify your identity before taking action on your request.9.1 Purposes and Legal Basis for Processing.The purposes for processing are described in detail in Section 2 (“HOW WE USE PERSONAL DATA”). In the use of our Services when we act as data controller the legal basis for processing is as follows:Provide, Maintain, and Support the Services (Section 2.1): This use is based on our legitimate interest to deliver the Services to you and for the performance of a contract.Improve, Personalize, and Develop Services (Section 2.2): This use is based on our legitimate interest to deliver the Services to you and for the performance of a contract.Provide, Personalize, Measure, and Improve our Advertising and Marketing (Section 2.3): This use is based on our legitimate interest in marketing our Services, for the performance of a contract, and is based on your explicit consent.Combine Contacts for Identity Resolution & Verification Services (Section 2.4): This use is necessary to deliver certain Services to you in the performance of a contract, is based on our legitimate interest, and is based on your explicit consent.Combine Contacts for Contact Enrichment Services (Section 2.5): This use is necessary to deliver certain Services to you in the performance of a contract, is based on our legitimate interest, and is based on your explicit consent.Creation of Deidentified, Aggregate, or Anonymous Information (Section 2.6): This use is based on our legitimate interests to improve and market our Services.9.2 Categories of Recipients of Data.Recipients of data are detailed in Section 3 (“HOW PERSONAL DATA IS SHARED”).9.3 Rectification of Inaccurate or Incomplete Information.You have the right to ask us to correct inaccurate or incomplete Personal Data concerning you (and which you cannot update yourself within your GrowthCode Account).9.4 Data Access and Portability.In some jurisdictions, applicable law may entitle you to request copies of your Personal Data held by us. You may also be entitled to request copies of Personal Data that you have provided to us in a structured, commonly used, and machine-readable format, or request us to transmit this information to another service provider (where technically feasible).9.5 Withdrawing Consent and Restriction of Processing.Where you have provided your consent to the processing of your Personal Data by GrowthCode you may easily withdraw your consent at any time specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Data, in particular where (a) you contest the accuracy of your Personal Data; (b) the processing is unlawful and you oppose the erasure of your Personal Data; (c) we no longer need your Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (d) you have objected to the processing pursuant to section below titled “Objection to Processing” and pending the verification whether the legitimate grounds of GrowthCode override your own.9.6 Objection to Processing.In some jurisdictions, applicable law may entitle you to require GrowthCode not to process your Personal Data for certain specific purposes, where such processing is based on legitimate interest. If you object to such processing we will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defense of legal claims.Where your Personal Data is processed for direct marketing purposes, you may, at any time, ask us to cease processing your Personal Data for these direct marketing purposes by sending an email to: opt-out@GrowthCode.io.9.7 Lodging Complaints.You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities. If you are an EEA resident, you have the right to file a complaint with your applicable data protection authority.EXERCISING YOUR PRIVACY RIGHTSWhen exercising the rights or options described in this Privacy Policy, the following guidelines apply:10.1   No Fee Usually Required.You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights).  However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.10.2   What We May Need from You.When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose your Personal Data to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.10.3   Time to Respond.We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.10.4   No Discrimination.You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.10.5   Authorized Agent.You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s identification information, and the authorized agent’s identification information.CHANGES TO THIS PRIVACY POLICYThis Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address associated with your Account, or by prominently posting notice of the changes on our Site. If any changes materially affect the manner in which we use or disclose Personal Data, we will provide advance notice of the change by email to the last email address associated with your Account, or by prominently posting notice of the changes on our Site. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.HOW TO CONTACT USIf you have any questions or complaints about this Privacy Policy, please contact us at: privacy@GrowthCode.ioOrganization:GrowthCode a d/b/a company of Capital Strategies, LLC. (a Delaware Company)47 East 88th Street#8BNew York, NY 10128To exercise your choices or opt out rights as described in this Privacy Policy, please use the following webform: “Own Your Personal Data”.Addendum – 1.1 GrowthCode EU Privacy Shield Certification InformationEU-US Privacy Shield CertificationThe following information aligns GrowthCode Privacy Statement with the specific points required by the Privacy Shield self-certification process, and ensures GrowthCode’s compliance with the EU-US Privacy Shield Framework.GrowthCode complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. GrowthCode has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.govIn compliance with the EU-US Privacy Shield Principles, GrowthCode commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact the dedicated GrowthCode compliance team at: privacy@GrowthCode.ioGrowthCode has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.GrowthCode is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).”Organization InformationGrowthCode a d/b/a company of Capital Strategies, LLC. (a Delaware Company)47 East 88th Street#8BNew York, NY 10128