Privacy Policy

Last Updated: June 10, 2025

1. Introduction

Clover Growth Partners (“we,” “us,” “our,” or “Company”) is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us in any way.

By accessing our website or using our services, you consent to the data practices described in this Privacy Policy.

2. Information We Collect

2.1 Data Minimization Principle

We collect only personal information that is necessary for the specific, explicit, and legitimate purposes outlined in this policy. We do not collect excessive or irrelevant personal information beyond what is required to provide our services effectively.

2.2 Personal Information You Provide

Contact Information: Name, email address, phone number, mailing address
Account Information: Username, password, profile information, account preferences
Payment Information: Credit card details, billing address, transaction history, payment method preferences
Communication Data: Messages, feedback, survey responses, support requests, training evaluations
Professional Information: Company name, job title, business information, industry sector, role responsibilities
Event Information: Registration details for workshops, seminars, training events, dietary preferences, accessibility needs

2.3 Information Automatically Collected

Device Information: IP address, browser type and version, operating system, device identifiers, screen resolution
Usage Data: Pages visited, time spent on site, clickstream data, referral sources, search queries, interaction patterns
Location Data: General geographic location based on IP address (country, state/province, city level)
Cookies and Tracking: Information collected through cookies, web beacons, pixels, and similar tracking technologies

2.4 Information from Third Parties

Social Media: Information from social media platforms when you connect your accounts or engage with our content
Business Partners: Information from authorized partners, affiliates, and referral sources
Public Sources: Publicly available professional information that supplements your profile
Data Enrichment Services: Professional contact information from legitimate data providers

3. Data Processing Legal Basis

We process your personal information based on the following legal grounds:

Consent: Where you have provided specific consent for processing
Contract Performance: Processing necessary to fulfill our contractual obligations to you
Legitimate Interests: Processing necessary for our legitimate business interests, balanced against your privacy rights
Legal Compliance: Processing required to comply with applicable laws and regulations

4. How We Use Your Information

4.1 Service Provision

Provide and maintain our training and consulting services
Process transactions and manage your account securely
Deliver educational content, training materials, and personalized learning experiences
Facilitate communication and customer support
Customize content based on your preferences and learning progress

4.2 Communication

Send transactional emails and important account notifications
Provide customer service and technical support
Send marketing communications (with your explicit consent)
Respond to your inquiries and requests promptly
Conduct satisfaction surveys and collect feedback

4.3 Business Operations and Analytics

Analyze usage patterns to improve our services and user experience
Conduct research and development for new products and services
Perform data analytics and generate business insights
Maintain and improve website security and functionality
Conduct internal training and quality assurance

4.4 Legal and Security Compliance

Comply with legal obligations and regulatory requirements
Detect, prevent, and address fraud, security issues, and abuse
Enforce our terms of service and policies
Protect our rights, property, and interests
Respond to law enforcement and legal requests

5. Data Protection Impact Assessments (DPIA)

We conduct Data Protection Impact Assessments when processing activities are likely to result in high risk to individual rights and freedoms, including:

Use of new technologies that may impact privacy
Processing large volumes of special categories of personal data
Systematic monitoring of individuals
Automated decision-making with legal or significant effects

DPIA results inform our privacy protection measures and risk mitigation strategies.

6. Data Retention Periods

We retain personal information for specific periods based on data type and legal requirements:

Account Information: Retained for the duration of your account plus 3 years after closure
Financial/Transaction Data: Retained for 7 years as required by tax and financial regulations
Marketing Data: Retained for 3 years from last interaction, or until opt-out
Customer Support Records: Retained for 5 years from last contact
Website Analytics Data: Retained for 2 years in aggregated, anonymized form
Legal and Compliance Records: Retained as required by applicable laws (typically 7-10 years)

When retention periods expire, we securely delete or anonymize personal information unless longer retention is required by law.

7. Information Sharing and Disclosure

7.1 Service Providers and Processors

We may share information with trusted third-party service providers who assist us in:

Payment processing and financial services (PCI DSS compliant processors)
Email marketing and communication services (subject to Data Processing Agreements)
Analytics and website optimization tools
Customer support and technical services
Cloud hosting and data storage (with appropriate security measures)
Legal and professional services

All third-party processors are required to maintain GDPR-compliant Data Processing Agreements and undergo regular security audits.

7.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction. We will provide notice and ensure equivalent privacy protections.

7.3 Legal Requirements and Protection

We may disclose information when required by law, court order, or government regulation, or when we believe disclosure is necessary to:

Comply with legal obligations and regulatory requirements
Protect our rights, property, and legitimate business interests
Prevent fraud, illegal activities, or security threats
Ensure user safety and platform integrity
Respond to emergency situations

7.4 International Data Transfers

When transferring personal information outside your country of residence, we implement appropriate safeguards including:

Standard Contractual Clauses (SCCs) approved by relevant data protection authorities
Data Protection Addendums with all international service providers
Adequacy Decisions where available from relevant regulatory bodies
Binding Corporate Rules for intra-group transfers

8. Enhanced Data Security Measures

We implement comprehensive technical and organizational security measures:

8.1 Technical Safeguards

Encryption: AES-256 encryption for data at rest and TLS 1.3 for data in transit
Access Controls: Multi-factor authentication and role-based access controls
Network Security: Firewalls, intrusion detection systems, and network monitoring
Regular Security Audits: Quarterly penetration testing and vulnerability assessments
Secure Development: Security-by-design principles in all system development

8.2 Organizational Safeguards

Employee Training: Mandatory annual privacy and security training for all staff
Background Checks: Comprehensive screening for employees with data access
Incident Response Plan: Documented procedures for security breach response
Privacy by Design: Privacy considerations integrated into all business processes
Third-Party Audits: Annual security assessments by independent auditors

8.3 Data Breach Response

In the event of a data breach, we will:

Notify Regulatory Authorities within 72 hours where legally required
Notify Affected Individuals without undue delay when high risk is determined
Provide Detailed Information about the breach, affected data, and mitigation steps
Implement Remedial Measures to prevent future incidents
Document All Actions taken in response to the breach

9. Your Rights and Choices

9.1 Access and Portability Rights

Right of Access: Request confirmation of processing and access to your personal information
Data Portability: Receive your data in a structured, commonly used, machine-readable format
Information About Processing: Details about purposes, categories, and retention periods

9.2 Correction and Update Rights

Right to Rectification: Correct inaccurate or incomplete personal information
Account Management: Update your information through account settings
Verification Process: Identity verification may be required for sensitive changes

9.3 Deletion and Restriction Rights

Right to Erasure: Request deletion of your personal information under specific circumstances
Right to Restriction: Limit processing of your personal information in certain situations
Account Closure: Permanently delete your account and associated data

9.4 Objection and Consent Management

Right to Object: Object to processing based on legitimate interests or for direct marketing
Consent Withdrawal: Withdraw consent for specific processing activities
Automated Decision-Making: Object to decisions based solely on automated processing

9.5 Communication Preferences

Marketing Opt-Out: Unsubscribe from marketing communications at any time
Granular Controls: Manage specific types of communications separately
Preference Center: Comprehensive communication preference management

10. Cookies and Tracking Technologies

We use various tracking technologies including:

Essential Cookies: Required for website functionality and security
Analytics Cookies: Collect usage statistics and performance data
Marketing Cookies: Enable targeted advertising and campaign measurement
Preference Cookies: Remember your settings and preferences

You can control cookie settings through your browser or our cookie preference center. Disabling certain cookies may limit website functionality.

11. California Privacy Rights (CCPA/CPRA)

California residents have specific rights under the California Consumer Privacy Act and California Privacy Rights Act:

11.1 Right to Know

Categories of Information: What personal information we collect and process
Sources of Information: Where we obtain personal information
Business Purposes: Why we collect and use personal information
Third-Party Sharing: With whom we share personal information

11.2 Right to Delete

Deletion Requests: Request deletion of personal information we have collected
Verification Process: Identity verification required for deletion requests
Exceptions: Certain information may be retained for legal compliance

11.3 Right to Opt-Out

Sale of Information: We do not sell personal information to third parties
Sharing for Advertising: Opt out of sharing for cross-context behavioral advertising
Sensitive Information: Control use of sensitive personal information

11.4 Right to Non-Discrimination

Equal Service: No discrimination for exercising your privacy rights
No Retaliation: Protection against adverse treatment for privacy requests

To exercise these rights, contact us at admin@growwithclover.com or use our online privacy request form.

12. European Union Rights (GDPR)

If you are in the European Union, you have additional rights under the General Data Protection Regulation:

12.1 Supervisory Authority

Right to Complaint: File complaints with your local data protection authority
Contact Information: EU representative contact details available upon request

12.2 Legal Basis Transparency

Processing Grounds: Clear explanation of legal basis for each processing activity
Consent Management: Granular consent controls for optional processing

13. Children’s Privacy Protection

Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected such information, we will:

Immediate Deletion: Delete the information promptly upon discovery
Parental Notification: Contact parents/guardians when possible
Process Review: Review and strengthen age verification measures

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, services, or applicable laws. We will provide notice of material changes through:

Website Notification: Prominent notice on our website for 30 days
Email Notification: Direct email to registered users for significant changes
Version Control: Maintain previous versions for reference
Effective Date Updates: Clear indication of when changes take effect

15. International Privacy Frameworks

We comply with applicable international privacy frameworks including:

EU-US Data Privacy Framework: For transfers to the United States
UK GDPR: For processing of UK residents’ data
Swiss Data Protection Act: For Swiss resident data processing

16. Contact Information and Data Protection Officer

For privacy-related questions, concerns, or to exercise your rights:

Privacy Officer
Clover Growth Partners
Email: admin@growwithclover.com

Response time: We will respond to privacy requests within 30 days (or as required by applicable law).