Privacy Policy

This Privacy Policy ("Policy") describes how 9629033 Canada INC, doing business as GrowthTurbine ("GrowthTurbine," "we," "us," or "our"), collects, uses, discloses, and protects personal information obtained through our website at growthturbine.com (the "Website") and any related services, features, content, applications, and products (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with this Policy, you must discontinue use of the Services immediately.

GrowthTurbine is a marketing agency specializing in investor acquisition for equity crowdfunding campaigns, including Regulation CF, Regulation D 506(c), Regulation A+, tokenized securities, and private fund placements. This Policy applies to all visitors, users, clients, and any other individuals whose personal information we process in connection with our Services.

2.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us when you:

• Submit a contact form or inquiry (name, email address, phone number, company website, funding goals, marketing budget, and project details)
• Subscribe to our newsletter or marketing communications
• Apply for employment through our careers page
• Register as an investor through our investor network
• Communicate with us via email, phone, or other channels
• Engage our Services under a client agreement

2.2 Information Collected Automatically

When you visit our Website, we automatically collect certain technical information, including:

• IP address, browser type and version, operating system, and device identifiers
• Pages visited, time spent on pages, referring URLs, and navigation paths
• Cookies, pixel tags, web beacons, and similar tracking technologies
• Geolocation data (approximate, derived from IP address)
• Log files, server logs, and usage data generated by your interaction with the Website

2.3 Information from Third Parties

We may receive personal information about you from third-party sources, including:

• Advertising platforms (Google Ads, Meta/Facebook Ads, LinkedIn Ads)
• Analytics services (Google Analytics)
• Equity crowdfunding platforms and transfer agents
• Publicly available sources, including LinkedIn profiles and corporate filings

We use the personal information we collect for the following purposes:

• To provide, operate, maintain, and improve our Services
• To respond to your inquiries, requests, and communications
• To process and manage client engagements, including investor acquisition campaigns
• To send marketing communications, newsletters, and promotional materials (with your consent where required by law)
• To personalize your experience and deliver targeted advertising and content
• To analyze usage trends, monitor the effectiveness of our marketing campaigns, and improve our Website
• To detect, prevent, and address fraud, security breaches, and technical issues
• To comply with applicable laws, regulations, and legal processes, including securities regulations
• To enforce our terms and conditions and protect our rights, property, and safety
• To facilitate business transactions, such as mergers, acquisitions, or asset sales

Where applicable law requires a legal basis for processing personal information (such as under PIPEDA, GDPR, or similar legislation), we rely on the following:

• Consent: Where you have provided explicit consent to the processing of your personal information for one or more specific purposes (e.g., subscribing to marketing communications).
• Contractual Necessity: Where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, such as marketing our Services, improving our Website, and preventing fraud, provided that such interests are not overridden by your rights and freedoms.
• Legal Obligation: Where processing is necessary to comply with a legal obligation to which we are subject, including applicable securities regulations and anti-money laundering requirements.

We do not sell your personal information. We may share your personal information with the following categories of recipients:

• Service Providers: Third-party vendors who perform services on our behalf, such as web hosting, email delivery, analytics, advertising, customer relationship management, and payment processing. These providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.
• Equity Crowdfunding Platforms: Where necessary to facilitate investor acquisition campaigns on platforms such as Wefunder, Republic, StartEngine, DealMaker, Dalmore, and others.
• Legal and Regulatory Authorities: Where required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers: In connection with any merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity.
• With Your Consent: We may share your information for any other purpose disclosed to you at the time of collection or with your consent.

We use cookies and similar tracking technologies to collect information about your browsing activity on our Website. Cookies are small data files stored on your device that help us improve our Services and your experience.

Types of cookies we use:

• Strictly Necessary Cookies: Essential for the operation of our Website. These cannot be disabled.
• Performance/Analytics Cookies: Help us understand how visitors interact with our Website by collecting information anonymously (e.g., Google Analytics).
• Functionality Cookies: Enable enhanced functionality and personalization, such as remembering your preferences.
• Targeting/Advertising Cookies: Used to deliver relevant advertisements and track the effectiveness of our marketing campaigns (e.g., Meta Pixel, Google Ads conversion tracking, LinkedIn Insight Tag).

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our Website. Most browsers allow you to refuse or delete cookies. Instructions for managing cookies vary by browser; please refer to your browser's help documentation.

Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC ("Google"), to analyze usage patterns on our Website. Google Analytics uses cookies to collect information about your activity, which is transmitted to and stored by Google on servers in the United States. Google may use this data to contextualize and personalize ads within its own advertising network. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

Cloudflare Turnstile

We use Cloudflare Turnstile, a security service provided by Cloudflare, Inc., to protect our contact form from automated spam submissions. Turnstile may collect certain technical data (such as browser characteristics and interaction patterns) to verify that submissions are made by humans. This data is processed by Cloudflare in accordance with its privacy policy.

Advertising Platforms

We use third-party advertising platforms, including Google Ads, Meta (Facebook) Ads, and LinkedIn Ads, for remarketing and conversion tracking purposes. These platforms may use cookies, pixels, and similar technologies to collect information about your visits to our Website and deliver targeted advertisements. You can manage your advertising preferences through:

• Google Ads Settings: adssettings.google.com
• Facebook Ad Preferences: facebook.com/adpreferences
• LinkedIn Ad Preferences: linkedin.com/psettings/advertising
• Network Advertising Initiative Opt-Out: optout.networkadvertising.org
• Digital Advertising Alliance Opt-Out: optout.aboutads.info

We retain your personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. The retention period may vary depending on the context of the processing and our legal obligations.

• Contact form submissions and inquiry data: retained for up to 3 years from the date of submission, unless a client relationship is established.
• Client engagement data: retained for the duration of the client relationship and for up to 7 years thereafter to comply with applicable legal and regulatory requirements.
• Marketing communication preferences: retained until you withdraw your consent or unsubscribe.
• Website analytics data: retained in accordance with our analytics provider's standard retention policies (e.g., Google Analytics data is retained for 26 months by default).

When personal information is no longer required, we will securely delete or anonymize it in accordance with applicable law.

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption of data in transit using TLS/SSL protocols
• Access controls limiting data access to authorized personnel on a need-to-know basis
• Regular security assessments and monitoring of our systems
• Secure data storage with reputable cloud service providers
• Cloudflare Turnstile CAPTCHA protection on forms to prevent automated spam and bot submissions

While we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security, and you provide personal information at your own risk.

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

• Right of Access: You may request a copy of the personal information we hold about you.
• Right of Rectification: You may request that we correct any inaccurate or incomplete personal information.
• Right of Erasure: You may request that we delete your personal information, subject to certain legal exceptions.
• Right to Restrict Processing: You may request that we restrict the processing of your personal information in certain circumstances.
• Right to Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: You may object to the processing of your personal information for direct marketing purposes or where processing is based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us using the information provided in Section 17 below. We will respond to your request within the timeframe required by applicable law. We may request additional information to verify your identity before processing your request.

Canadian Residents (PIPEDA)

If you are a resident of Canada, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), including the right to access and correct your personal information. You may also file a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

EEA/UK Residents (GDPR)

If you are a resident of the European Economic Area or the United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR) or UK GDPR, including the right to lodge a complaint with your local data protection authority.

California Residents (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including the right to know what personal information is collected, the right to delete, the right to opt out of the sale or sharing of personal information, and the right to non-discrimination. We do not sell personal information as defined under the CCPA/CPRA.

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe that a child has provided us with personal information, please contact us immediately using the information in Section 17.

GrowthTurbine is based in Canada. Your personal information may be transferred to, stored, and processed in Canada or other countries where our service providers maintain facilities. These countries may have data protection laws that differ from those in your jurisdiction. By using our Services, you consent to the transfer of your personal information to Canada and other jurisdictions as described in this Policy.

Where required by applicable law, we implement appropriate safeguards for international data transfers, including standard contractual clauses or reliance on adequacy decisions.

Our Website may contain links to third-party websites, applications, or services that are not operated by us. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party sites you visit. This Policy applies solely to information collected by GrowthTurbine through our Services.

We use third-party email service providers to manage our marketing communications and transactional emails. These providers process personal information (such as email addresses) on our behalf and are contractually obligated to protect your information.

You may unsubscribe from marketing communications at any time by clicking the "unsubscribe" link in any marketing email or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you transactional or service-related communications.

We use remarketing and retargeting technologies to display relevant advertisements to users who have previously visited our Website. These technologies use cookies and similar identifiers to deliver ads based on your past interactions with our Services.

Our advertising partners may combine information collected from our Website with information from other sources to provide you with targeted advertising across different platforms and devices. You can opt out of interest-based advertising by adjusting your browser settings, using the opt-out tools listed in Section 7, or by enabling the "Do Not Track" signal in your browser (where supported by the advertising platform).

We reserve the right to update or modify this Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where required by applicable law, provide you with notice of such changes (e.g., by posting a notice on our Website or sending an email). Your continued use of the Services after any changes to this Policy constitutes your acceptance of the updated Policy.

We encourage you to review this Policy periodically to stay informed about how we collect, use, and protect your information.

The data controller responsible for your personal information is: