1. Introduction

Welcome to The Growth Bully Ltd. (also operating under the name breezflo) ("we," "us," or "our"). We are committed to protecting your personal data and respecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you interact with our services, including our websites www.thegrowthbully.com and www.breezflo.com, and through forms provided by Typeform and email communications via Mailchimp.

2. Data Controller

The Growth Bully Ltd. (operating as breezflo)

• Address: 47, Marjo, Triq Antonio Schembri, Kappara, San Gwann SGN 4236, Malta
• Email: stephen@thegrowthbully.com
• VAT Registration No.: MT29182301
• Company Registration No.: C 102212

3. Information We Collect

We may collect and process the following types of personal data:

• Contact Information: Name, email address, phone number, and mailing address.
• Professional Information: Company name, job title, industry sector.
• Usage Data: Information about how you use our websites and services, including IP address, browser type, and browsing behavior.
• Marketing Preferences: Your preferences in receiving marketing communications from us.

4. How We Collect Your Data

• Direct Interactions: You may provide data by filling in forms on our websites (e.g., Typeform), subscribing to our newsletters, or corresponding with us by phone, email, or otherwise.
• Automated Technologies: As you interact with our websites, we may automatically collect technical data about your equipment and browsing actions through cookies and similar technologies.
• Third Parties: We may receive personal data about you from third-party service providers like Mailchimp.

5. Use of Your Information

We use your personal data for the following purposes:

• Provision of Services: To deliver the services and information you request.
• Marketing Communications: To send you updates, promotions, and marketing materials that may be of interest to you.
• Customer Support: To manage your inquiries and provide customer service.
• Legal Obligations: To comply with applicable laws, regulations, and legal processes.
• Analytics: To understand and improve our services through data analysis.

6. Legal Basis for Processing

We process your personal data based on:

• Consent: Where you have given explicit consent for one or more specific purposes.
• Legitimate Interests: Processing is necessary for our legitimate interests, such as improving our services, provided your interests and fundamental rights do not override those interests.
• Legal Obligation: Compliance with legal obligations to which we are subject.
• Performance of a Contract: Where processing is necessary for the performance of a contract with you.

7. Disclosure of Your Information

We may share your personal data with:

• Service Providers: Third-party vendors like Mailchimp and Typeform who assist in providing our services. These parties process data on our behalf and are obligated to not disclose or use it for other purposes.
• Legal Authorities: If required by law or in response to valid requests by public authorities.
• Business Transfers: In the event of a merger, acquisition, restructuring, or asset sale, including a change of company name to breezflo ltd.

8. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including countries that may not have data protection laws equivalent to those in the EEA.

When we transfer your data outside the EEA, we ensure that appropriate safeguards are in place to protect your personal data, including:

• Standard Contractual Clauses: We use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Data Privacy Frameworks: Where applicable, we may transfer data to entities in countries that the European Commission has deemed to provide an adequate level of data protection.
• Consent: In some cases, we will obtain your explicit consent for these transfers.

9. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. Access to your personal data is limited to those employees, agents, contractors, and other third parties who have a business need to know.

10. Data Retention

We will retain your personal data only as long as necessary to fulfill the purposes we collected it for, including legal, accounting, or reporting requirements. In the event of a company name change to breezflo ltd, we will continue to retain and process your data in accordance with this Privacy Policy unless otherwise notified.

11. Your Rights

Under the General Data Protection Regulation (GDPR) and other applicable laws, you have the following rights regarding your personal data:

• Access: Request access to your personal data.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data when there is no good reason for us to continue processing it.
• Restriction: Request restriction of processing your data in certain circumstances.
• Portability: Request the transfer of your data to you or to a third party.
• Objection: Object to processing of your data where we are relying on legitimate interests or for direct marketing purposes.
• Withdraw Consent: Withdraw consent at any time where we are relying on consent to process your data.

To exercise any of these rights, please contact us at stephen@thegrowthbully.com.

12. Cookies and Tracking Technologies

Our websites use cookies and similar technologies to enhance user experience, analyze site traffic, and for marketing purposes. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. For more information, please see our Cookie Policy.

13. Third-Party Links

Our websites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the privacy practices of these sites.

14. Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have inadvertently received personal data from a person under the age of 16, we will delete such information from our records.

15. Additional Safeguards for International Users

If you are accessing our services from outside the EU, please be aware that your information may be transferred to, stored, and processed in Malta and other countries where our servers are located and our central database is operated. By using our services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

16. Third-Party Service Providers Outside the EEA

We may use third-party service providers located outside the EEA, including in the United States, for services such as email marketing (Mailchimp) and data collection (Typeform). We ensure that these providers are compliant with GDPR requirements and that appropriate safeguards, such as Standard Contractual Clauses, are in place.

17. Business Transfers and Company Changes

In the event that we undergo a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, including a change of company name to breezflo ltd, your personal data may be among the assets transferred. You acknowledge that such transfers may occur and that the transferee may continue to use your personal data as set forth in this Privacy Policy.

We will notify you of any change in ownership or use of your personal data, as well as any choices you may have regarding your personal data, by posting updates on our websites and, where appropriate, contacting you via email.

18. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any changes will be posted on this page with an updated revision date. We encourage you to review this Privacy Policy periodically for any changes.

If we make material changes to this Privacy Policy, we will notify you by prominently posting a notice on our websites or by contacting you directly.

20. Contact Us

For any questions or concerns regarding this Privacy Policy or our data practices, please contact us at:

• Email: stephen@thegrowthbully.com
• Address: 47, Marjo, Triq Antonio Schembri, Kappara, San Gwann SGN 4236, Malta