Privacy Policy

This Privacy Policy explains how Growth Tonic Ltd ("GrowthMentor", "we", "us", or "our") collects, uses, shares, and protects your personal data when you use our website and services. Growth Tonic Ltd is the data controller responsible for your personal data.

If you are in the EU/EEA or the UK, you have specific rights over your personal data. This policy describes them, and the companion GDPR & Your Rights page sets out how to exercise them in detail.

Controller: Growth Tonic Ltd, Thiseos 7, Office 101, 2042 Strovolos, Cyprus. VAT number CY10440770M. You can contact us about privacy at [email protected].

Information We Collect

Information you provide

When you register for an account, we may collect your name, company name, address, email address, and telephone number. When you add financial account information, it is sent to our third-party payment processor. If you contact us, we may collect your name, email address, phone number, and the contents of your message and any attachments. We also collect the content you submit to the platform, such as your profile, reviews, comments, help requests, and community messages.

Information we collect automatically

When you visit our website we may collect your IP address, device and browser information, and information about your visit (the pages you view and the time and duration of your visit), using cookies, web beacons, and similar technologies. In some countries, including those in the European Economic Area, this information may be considered personal data. See our cookies and tracking information below for more.

Session recording and AI data

When you use the GrowthMentor Video Room with recording enabled, we collect audio and video recordings of sessions, session transcripts and chat messages, engagement metrics, session metadata (timing, participants, topics), and your interactions with AI features. Recording is optional and you can disable it at any time (see "Session Recording and AI Processing" below).

How We Use Your Information and Our Legal Bases

We process your personal data for the following purposes, relying on the legal bases set out below (GDPR Article 6):

• To provide and operate our services — creating and managing your account, enabling mentor–mentee connections, processing bookings and payments, and providing customer support. Legal basis: performance of our contract with you.
• To enable session recording and AI features — generating summaries, takeaways, and recommendations for you. Legal basis: your consent, which you can withdraw at any time.
• To communicate with you — sending service messages and, where permitted, marketing and promotional messages. Legal basis: performance of our contract, your consent for marketing, and/or our legitimate interests.
• To improve, personalize, and develop our services — understanding how our services are used and developing new features. Legal basis: our legitimate interests in operating and improving our services.
• To keep our platform safe — detecting and preventing fraud, abuse, and security incidents. Legal basis: our legitimate interests and, where applicable, legal obligation.
• To comply with the law — meeting tax, accounting, and other legal obligations, and responding to lawful requests. Legal basis: compliance with a legal obligation.

Cookies and Tracking

We use cookies and similar technologies (including web beacons) to operate our website, remember your preferences, analyze usage, and, with your consent, for marketing. Non-essential cookies are only set with your consent, which you can manage through our cookie banner or your browser settings. Disabling some cookies may affect how the website functions. A web beacon is a small graphic embedded in pages or emails that helps us understand usage; it does not read personal information other than usage statistics.

Session Recording and AI Processing

How we use recording data

We process recorded session data to generate session summaries and key takeaways, provide AI-powered learning recommendations, let you review your sessions, and analyze session effectiveness for your benefit. We do not use your recordings, transcripts, or their content to train our own or any third party's AI models.

Your control over recording data

You can manage your recording preferences in your account settings: enable or disable recording, control recording for individual sessions, access and download your recordings, request deletion of specific recordings, and manage sharing settings. We clearly indicate recording status during scheduling, before a session starts, and throughout a recorded session.

How long we keep recording data

• Active accounts: for the duration of account activity.
• Deleted accounts: 30 days following a deletion request.
• Individual recordings: until deleted by you or as required by law.

How We Share Your Information

We do not sell your personal data. We share it only with:

• Service providers (processors) who process data on our behalf under contract, including: Stripe (payment processing), Agora (video conferencing infrastructure), OpenAI (AI processing), analytics providers (such as Google Analytics), and cloud hosting providers. Our processors are bound by confidentiality obligations, process data only on our instructions, and must implement appropriate security measures.
• Other users, where you choose to share information through the platform (for example, your public profile, reviews, or community posts).
• Authorities or third parties where required by law, to enforce our terms, or to protect the rights, safety, or property of GrowthMentor, our users, or others.
• A successor entity in connection with a merger, acquisition, reorganization, or sale of assets.

International Data Transfers

Some of our service providers are located outside the European Economic Area (for example, in the United States). Where we transfer your personal data outside the EEA, we rely on an adequacy decision of the European Commission, or on appropriate safeguards such as the European Commission's Standard Contractual Clauses, to ensure your data is protected to an equivalent standard. You can request more information about these safeguards at [email protected].

How Long We Keep Your Information

We keep your personal data for as long as your account is active and for as long as needed to provide our services. After that, we retain data only where necessary to comply with legal obligations (such as tax and accounting records), to resolve disputes, and to enforce our agreements. When data is no longer needed, we delete or anonymize it. See the recording-data and deletion sections for specific timeframes.

How We Protect Your Information

We implement appropriate technical and organizational measures to protect your personal data, including encryption in transit and at rest, access controls and authentication, regular security assessments, and secure processing environments. No method of transmission or storage is completely secure, but we work to protect your data and to respond appropriately to any incident.

Your Privacy Rights

Depending on where you live, you have rights over your personal data — including the rights to access, correct, delete, restrict, port, and object to the processing of your data, and to withdraw consent. If you are in the EU/EEA or the UK, the GDPR & Your Rights page explains these rights in full and how to exercise them, and your right to complain to a supervisory authority.

Data Deletion Requests

You can request deletion of your personal data at any time by emailing [email protected] with the subject line "Data Deletion Request" (include your full name and the email associated with your account), or through your account settings. We will verify your identity and permanently delete the requested data within 30 days, unless we are required by law to retain certain information.

Children's Privacy

Our services are intended solely for persons aged 18 or older. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, please contact us and we will delete it.

Automated Decision-Making

We use AI to support features such as mentor matching and session summaries. We do not make decisions that produce legal effects, or similarly significant effects, about you based solely on automated processing. Where AI is used, it supports — rather than replaces — meaningful human involvement.

Changes to This Policy

We may update this Privacy Policy from time to time. Where a change materially affects your rights, we will notify you. The "Last updated" date at the top of this page shows when it was last revised, and the current version is always available here.

Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, contact us at [email protected], or write to Growth Tonic Ltd, Thiseos 7, Office 101, 2042 Strovolos, Cyprus. If you are in the EU/EEA or the UK and are not satisfied with our response, you have the right to lodge a complaint with a data protection supervisory authority — see the GDPR & Your Rights page.