Privacy Policy

1. Introduction

Welcome to Framework, a cloud-based brand management Software-as-a-Service (“Platform”) provided by Growth Alliance LLC, a Wyoming limited liability company ("Growth Alliance", "we", "us", "our").

We are committed to protecting your personal information and your right to privacy. This Privacy Policy describes how we Process Personal Data of individuals (“You”) who use the Platform, visit our websites, or interact with us in other ways.

This policy should be read in conjunction with our Terms of Service. By using the Platform, you agree to the collection and use of information in accordance with this policy.

2. Definitions

For the purpose of this Privacy Policy, the following definitions apply:

"Personal Data", “Data Subject”, “Processor”, “Controller”, and “Processing” shall have the meaning given to them by the EU General Data Protection Regulation (GDPR).
Additional terms shall have the meaning provided in this Privacy Policy or our Terms of Service.

3. What is our role in processing your data?

It is important to understand our role regarding your data.

Growth Alliance as a Processor: When you upload your content (logos, images, text, etc., known as "Client Materials") to our Platform, you are the Controller of that data. We act as a Processor, handling that data on your behalf and according to your instructions to provide the Service.
Growth Alliance as a Controller: For other types of data, such as your account information, billing details, and data about how you use our Platform, we are the Controller. We determine the purposes and means of processing this data to manage our service and business.

4. What information do we collect and how do we use it?

This section details the different processing activities we perform.

a) Personal Information You Disclose to Us (We act as Controller)We collect personal information that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us, or when you contact us. This includes:

Data Processed: Name, work email address, phone number, company name, job title, usernames, and passwords.
Purpose: To create and manage your account, provide customer support, and send you essential service-related communications.
Lawful Basis: Processing is necessary for the performance of a contract (our Terms of Service) with you.

b) Billing Information (We act as Controller)When you purchase a Subscription, we collect:

Data Processed: Name, billing address, and credit card information.
Purpose: To process payments for our services. Note: We do not store full credit card information ourselves; this is handled by our secure third-party payment processor, Stripe.
Lawful Basis: Processing is necessary for the performance of a contract.

c) Information Automatically Collected (We act as Controller)We automatically collect certain information when you visit or use the Platform. This information does not reveal your specific identity but may include:

Log and Usage Data: IP address, browser and device characteristics, operating system, language preferences, referring URLs, and information about how and when you use our Platform.
Device Data: Information about your computer, phone, or tablet, such as hardware model and operating system.
Purpose: To maintain the security and operation of our Platform, and for our internal analytics and reporting purposes.
Lawful Basis: We rely on our legitimate interest to operate and improve our services.

d) Platform User Information (We act as Processor)To provide our core services, we process the following data on behalf of our Clients:

Data Processed: Name, email address, profile picture, job title, and any Personal Data contained within the "Client Materials" you upload.
Purpose: To allow users to log in, use the Platform's features, and create content.
Lawful Basis: As a Processor, we process this data based on the instructions of our Client (the Controller).

e) Marketing and Testimonials (We act as Controller)

Marketing Communications: We may use your name and email to send you marketing materials. You can unsubscribe at any time. The lawful basis is our legitimate interest.
Testimonials: We will always obtain your explicit consent before publishing a testimonial that includes your Personal Data.

5. Will your information be shared with anyone?

We do not sell your Personal Data. We may share information with your consent, to comply with laws, to provide you with services, to protect our rights, or to fulfill business obligations.

We share and disclose your information only with the following third parties:

Communicate and Chat with Users: Postmark
Invoice and Billing: Stripe
Web and Mobile Analytics: Vercel
Website Performance Monitoring: Vercel
Cloud Hosting: Amazon Web Services (AWS)

We may also share information during Business Transfers, such as a merger or acquisition.

6. How do we handle your data? (Security, Retention & Transfers)

Security: We use appropriate technical and organizational security measures to protect your personal information. However, no electronic transmission or storage technology can be guaranteed to be 100% secure.
Retention: We retain your Personal Data only for as long as necessary for the purposes set out in this policy, unless a longer period is required by law. Data in your account will typically be deleted within 30 days of termination.
Data Storage and International Transfers: We are a US-based company. Your Personal Data is stored on secure servers located in the United Kingdom. If you are accessing our Platform from outside the UK, your information will be transferred to, stored, and processed in the UK. We ensure appropriate safeguards are in place for all data transfers.

7. What are your privacy rights?

Depending on where you live – for example, in the European Economic Area – you may have specific rights that give you greater control over how your personal data is used. You can view, update, or close your account at any time.

In regions such as the European Economic Area, data protection laws may entitle you to a range of rights regarding your personal information. These can include the ability to: (i) access and receive a copy of your data; (ii) request corrections or deletion; (iii) limit how your data is processed; and (iv) in some cases, request that your data is transferred to another provider. You may also have the right to object to how your data is handled, depending on the situation. If you’d like to make a request, please use the contact details at the end of this notice. We will review and respond to any requests in line with relevant data protection laws.

Where we rely on your consent to process data, you can withdraw that consent at any time. This won’t affect any processing that was carried out lawfully before your consent was withdrawn, nor will it impact any processing done under other lawful grounds.

If you’re based in the European Economic Area and believe your data is being handled unlawfully, you have the right to raise a concern with your local data protection authority. You can find contact information here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

For individuals in Switzerland, details for the appropriate data protection authority are available at: https://www.edoeb.admin.ch/edoeb/en/home.html.

8. Do we have controls for do-not-track features?

Most web browsers include a Do-Not-Track ("DNT") feature. As there is no uniform technology standard for recognizing and implementing DNT signals, we do not currently respond to DNT browser signals.

9. Do we collect information from minors?

Our Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18.

10. Do we make updates to this notice?

We may update this policy from time to time. The updated version will be indicated by the "Last Updated" date.

11. How can you contact us about this notice?

If you have any questions, please contact us at: team@thegrowthalliance.com.

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