Privacy policy

1. Data controller

The controller for the processing described below is Growthwing (SAS being incorporated), whose details appear in the Legal notice.

For any question about your personal data, you may contact us at talk@growthwing.ai.

Given the nature and volume of the processing, appointing a Data Protection Officer (DPO) is not mandatory; talk@growthwing.ai is the single point of contact for any request.

2. Data we collect

The site is currently in a pre-launch phase. We only collect the data you voluntarily provide through our forms:

• Waitlist: first name, last name, work email, company, job role, and a short identifier generated automatically on sign-up.
• Booking: first name, last name, work email, company, job role, and the date and time of the chosen slot.
• Acquisition measurement: for internal statistics, the source you arrived from (URL UTM parameters, landing page and referring site), recorded without any cookie or third-party advertising tracker.

We collect no special-category data within the meaning of Article 9 GDPR. We carry out no profiling and no solely automated decision-making producing legal effects concerning you (Article 22 GDPR).

3. Purposes and legal bases

Each processing activity relies on its own legal basis:

• Waitlist — Purpose: record your interest, send you a confirmation email and inform you when the service opens. Legal basis: your consent (Article 6(1)(a) GDPR), given by voluntarily submitting the form. You may withdraw it at any time via the unsubscribe link in every email.
• Booking — Purpose: arrange and hold a 30-minute video call at your request, by creating a Google Calendar event with a Google Meet link. Legal basis: steps taken at your request prior to entering into a contract (Article 6(1)(b) GDPR).

4. Retention periods

In line with the French data protection authority (CNIL) guidance on prospect management, your data is kept for a maximum of three (3) years from your last contact with Growthwing.

If you unsubscribe, your data is deleted immediately. Some data may be kept longer where a legal obligation or the defence of a right requires it.

5. Recipients and processors

Your data is handled by Growthwing’s authorised staff and by the following processors, each bound by a data processing agreement under Article 28 GDPR:

• Google (Google Calendar and Google Meet) — to create the booking event and the video-call link.
• Our email delivery provider (SMTP) — to send confirmation and unsubscribe emails.
• Our host / infrastructure operator — to run the servers.
• Our database (self-hosted PostgreSQL / Supabase) — to store sign-ups.

We do not sell or rent your data to third parties. The site uses no advertising network and no audience-measurement tool.

6. Transfers outside the European Union

When you book a call, certain data (name, email) is transmitted to Google and may be processed in the United States. This transfer is governed by the European Commission’s “EU-US Data Privacy Framework” adequacy decision of 10 July 2023, Google LLC being certified under that framework, and, as a subsidiary safeguard, by the European Commission’s standard contractual clauses.

Joining the waitlist involves no such transfer. You can avoid this transfer by not booking a call.

7. Cookies and trackers

The growthwing.ai site uses no advertising cookies and no audience-measurement or analytics tool (no Google Analytics, no third-party tracker).

The only storage used in your browser is local storage (localStorage), used to remember your display language and your acquisition source (UTM parameters and referring site). Being strictly functional and for internal measurement, with no cookie or third-party advertising tracker, it is exempt from consent under Article 82 of the French Data Protection Act, so no consent banner is required. You can delete it at any time through your browser settings.

8. Your rights

In accordance with Articles 15 to 22 GDPR, you have the following rights: access, rectification, erasure, restriction, objection, portability, and withdrawal of consent at any time.

You may exercise these rights by writing to talk@growthwing.ai (proof of identity may be requested in case of doubt). You also have the right to lodge a complaint with the CNIL — 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France — www.cnil.fr.

9. Security

Growthwing implements appropriate technical and organisational measures to protect your data: encryption in transit (HTTPS), access restricted to authorised staff, and data minimisation.

10. Contact

For any question about this policy or to exercise your rights, write to us at talk@growthwing.ai.