Privacy Policy

Date modified April 10, 2019
I. Introduction

This Privacy Policy for Website visitors and Clients (“Privacy Policy) applies to Information (as defined below) about individuals and businesses or other entities that visit our Websites or obtain services (“Services”) for business or commercial purposes (Client(s), “you”, “your”) from B.V. (“GrowthSpot”, “we”, “our”, or “us”).

This Privacy Policy also addresses our use of Information obtained from Client’ use of our website that is accessible at (collectively, “Websites”). GrowthSpot provides marketing analytics for clients primarily through a marketing automation platform that manages, measures and automates interactions between our clients and their customers, at our Client’s request and direction during the marketing process. By using the Websites and the Services, Client consents to our collection, use and disclosure practices, and other activities as described in this Privacy Policy.

For purposes of this Privacy Policy, Information; means any information about you from which you could be identified, whether obtained directly from you or from another source. Information may include but is not limited to: (a) company name; (b) physical address, including street name and name of city or town; (c) email address or other electronic contact information; (d) telephone number; (e) first and/or last name; (f) IP address; (g) information about officers, directors, and other control persons; and (h) any other information from or about you and/or your customers.

However, the following is not considered Information:

(a) aggregated or anonymous information that does not identify you and/or your customers and (b) information that GrowthSpot obtains from a public source (or knows to be available from a public source).

II. How We Gather Information

 We may gather and retain Information about you from the following sources relating to our provision of Services:

Applications for accounts with us or other forms that you provide to us;

  • Financial account activity and transactions (such as credit card information, payment history, account balances, and usage);
  • Information from visits to our Websites, your website and your use of Services (such as cookies, usage and transaction history, and other technical data that we use for security purposes and to enhance the online experience); and
  • Information we may receive from third parties, such as data and technical support providers.




    III. How We Share Information

  • GrowthSpot shares Information among and between its affiliates. You may not opt-out of this sharing.
  • GrowthSpot may also disclose Information to non-affiliated third parties for routine business reasons. For example, GrowthSpot may disclose Information to service providers and other third parties as necessary to provide Services requested by a Client.
  • GrowthSpot may also disclose Information to non-affiliated third parties in response to a subpoena, warrant, or court order, or as otherwise required or advisable considering applicable law or regulation. You may not opt-out of this sharing.
  • GrowthSpot may collect certain financial information that GrowthSpot receives in connection with the provision of its Services to a Client. GrowthSpot will not use or transfer such information for any purpose other than to facilitate the commercial transaction for which the information was originally provided.

IV. How to Change Your Privacy Options

We will share Information as described in Section III above unless you direct us otherwise by taking one of the below steps. Note that based on the sharing practices above, there are certain instances of sharing for which you may not opt out.

Write or email us at . Requests must include company name, address, contact telephone number, and account number(s) (if applicable) for the business entity(ies) opting out. Incomplete information will delay or possibly prevent our ability to honor your request.

Call GrowthSpot at +852-9747-6340. Our system will be updated to reflect your privacy preferences within thirty (30) days following receipt of the request with complete information.

If you have already shared with us your privacy preferences under this Privacy Policy, it is not necessary to contact us again. We will continue to honor the preferences you have provided.


V. Children’s Privacy

You must be at least 18 years old to access the Websites and Services. We do not knowingly collect, use or disclose Information about users of the Websites and Services who are under the age of 13 years of age.