Privacy Policy

Growth Simple Privacy Notice

Effective on: 2021-05-20

1. Introduction and Scope

GrowthSimple Inc. ("GrowthSimple", "we," "us," "our") takes the protection of personal data ("PII") very seriously. This Privacy Notice (the "Notice") describes our processing of PII that we may receive from of our customers or business partners in the GrowthSimple platform. This Notice does not apply to PII we collect by other means, such as PII that we receive directly through GrowthSimple own publicly accessible websites.

2. Controllership

In the context of this Notice, GrowthSimple acts as a data processor for the data we process.

3. Categories of PII

We may process the following types of PII:

  1. Name;
  2. Email address;
  3. Job title;
  4. Work address;
  5. Work phone number;
  6. Information relevant to sales, such as details about past or scheduled meetings;
  7. Web application usage data;
  8. IP address; and
  9. Any other type of PII our clients may choose to share with us.

4. How we Receive PII

We may receive PII in a variety of ways. For example:

  1. When clients upload PII to us, or when receive access to raw customer data from our clients
  2. When our clients enable our programmatic access to PII collected and stored by them
  3. As otherwise provided by our clients via technical means and integrations and
  4. From third party data brokers

5. Basis of Processing

Within the scope of this Notice, we will only process PII as instructed by our clients (the data controllers). When our engagement with a client ends, we will delete the PII submitted by that client within one month.

6. Purpose of Processing

The purposes for processing PII include:

  1. User Behavior Prediction which involves taking a list of customers and assigning a "score" to each customer based on the available data;
  2. Topical enrichment and
  3. Providing our clients with other services that they have specifically requested from us.

7. Sharing PII with Third Parties

We share PII with our service providers, that process PII on behalf of GrowthSimple. Such third parties include:

  1. Infrastructure service providers
  2. Data brokers and
  3. Analytics service providers.

Our service providers may be located outside of the United States; however, we will require that those third parties maintain at least the same level of confidentiality that we maintain for such PII. GrowthSimple remains liable for the protection of PII that we transfer to our service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing

Where such international PII transfers are regulated by the EU General Data Protection Regulation, we will transfer PII outside the European Economic Area in compliance with the said Regulation

GrowthSimple is managed and operates primarily out of the United States and India. We allow our Indian service provider, Synerzip, and its employees and agents to access your Personal Data for the purposes described in this policy (this sharing is in our legitimate interest)

8. Other Disclosure of PII

We may disclose PII:

  1. To the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders
  2. If we sell or transfer all or a portion of our company's business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change or
  3. To our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

If we must disclose PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of PII will maintain the privacy or security of said PII.

9. Access & Review

If you are a data subject about whom we store PII, you may have a right to request access to, and the opportunity to update, correct, or delete, such PII. You may also have the right to opt out of having your PII shared with third parties and to revoke your consent to our sharing your PII with third parties. You may also have the right to opt out if your PII is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. To submit such requests or raise any other questions, the affected data subjects should directly contact our client that submitted the PII to us.

10. Data Integrity & Security

GrowthSimple has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect PII from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction.

11. Binding Arbitration

If a dispute or complaint can't be resolved by us, nor through the dispute resolution program established by VeraSafe, data subjects may have the right to require that we enter into binding arbitration with the affected individual pursuant to the Privacy Shield's Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

12. Regulatory Oversight

GrowthSimple is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

13. Changes to this Privacy Notice

If we make any material change to this Notice, we will post the revised Notice to this web page and update the "Effective" date above to reflect the date on which the new Notice became effective.

14. Contact Us

If you have any questions about this Notice or our processing of PII, please contact our Arjun Saksena by email at, by phone at +1 (415) 215 1912, or by postal mail at:

GrowthSimple Inc.
Attn: Arjun Saksena
735 Sobrato Drive
Campbell, CA 95008

Please allow up to four weeks for us to reply.

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