Privacy policy

1.1 Identity and contact

The Service is published by a simplified joint-stock company (SAS) whose registration is in progress, referred to below as “Growthwing”. Until it is registered, the Service is operated by its founders.

Information about the publisher and the host is given in the website’s legal notice.

Any question about this Policy and any request to exercise data protection rights should be sent to: talk@growthwing.ai.

Growthwing has not appointed a data protection officer.

1.2 Terms used

The “Client” is the company or self-employed professional on whose behalf the Service is used. A “User” is any natural person holding an account giving access to the Service (the “Account”) linked to a Client, whatever their role: administrator, department head, member or self-employed professional.

A self-employed professional is a Client whose professional activity is carried on by a single person, who has a workspace for their sole use. Team messaging, calls and rooms and the organisation into departments are not offered to them: the passages of this Policy that describe them do not concern them.

“Client Content” means the information that Users enter, upload, dictate or make accessible to the Service, in particular by connecting a third-party service. It includes the deliverables and other results produced for the Client (the “Outputs”).

Client Content does not include what is said during the welcome and team composition interviews, nor their summary, which are processed under Growthwing’s responsibility (Article 3.2).

The “Virtual Collaborators” are the artificial intelligence systems of the Service, each presented with a first name, a portrait and a profession. A “Mission” is a task entrusted by a User to a team of Virtual Collaborators. The “Execution Engine” is the engine that carries out Missions, operated by Growthwing with a specialist provider.

1.3 Growthwing’s capacities

Growthwing acts as controller for the processing listed in Article 3.2: management of access requests, management of Accounts, authentication and security, the welcome interview and team composition, the early access programme, proof of acceptance of the contractual documents, support, audience measurement and internal management.

Growthwing acts as processor for the processing of Client Content, described in Article 3.3. The Client is the controller of that processing. Growthwing then processes the data only on the Client’s instructions, under the conditions of Annex 1 to the Terms.

The third-party services that the User connects to the Service (Google mail and calendar, banks and financial software) remain governed by the terms and policies of their publishers. Those publishers act towards the User as separate controllers.

1.4 Age requirement and audience of the Service

The Service is reserved for adult professionals acting for the purposes of their business. It is prohibited for persons under eighteen years of age and is not intended for consumers.

Growthwing does not knowingly collect data relating to minors. Where it finds that a request or an Account comes from a minor, it closes the Account without delay and deletes the corresponding data as soon as possible, subject to Article 3.5.

A person who uses the Service for private purposes, in breach of the Terms, has their data processed in accordance with this Policy. Growthwing may close their Account under the conditions laid down in the Terms.

1.5 Data subjects

This Policy is addressed to visitors to the website, to people who request an invitation, to Users and to people invited to view a Mission.

It also informs the people whose data appears in Client Content without their using the Service: correspondents of a connected mailbox, participants in a calendar event, business contacts, people mentioned in a document. Growthwing does not collect this data from them. Its processing is a matter for the Client, under the conditions of Article 7.3.

2.1 Data provided by the person

• Invitation request: surname, first name, business email address, optional telephone number, company, role in the company, free-text message.
• Account: email address, first name, surname, job title, password, optional photograph, language.
• Client: name, address identifier, SIRET number, VAT number, address, telephone, contact email, website, logo, VAT filing frequency, financial year-end month, whether there are employees, type of organisation, legal form. This information, most of which is optional, constitutes personal data where the Client is a self-employed professional.
• Welcome interview and team composition interviews: what the person says about themselves, their business and their needs, by voice or in writing.
• Account security: one-time authentication factor, backup codes, trusted devices.
• Correspondence: messages sent to Growthwing.

2.2 Data collected automatically

• Connection and security data: Account creation date, date of last login, approximate location of a trusted device inferred from the IP address using a database held on Growthwing’s server, without calling on any third-party service.
• Logs: actions carried out by Growthwing staff and access to the infrastructure, with the corresponding IP address; technical errors.
• Origin of a request: campaign parameters in the page address, address of the previous page and page path, recorded with an invitation request.
• Provider usage: for each call billed to Growthwing by a provider, the provider, the model, the units consumed, the cost, and the identifiers of the Client, User and Mission concerned. This log contains no Client Content.
• Trackers: described in Article 8.

2.3 Data received from third parties

• From the Client: where the Account is created by a Client administrator or by Growthwing staff at the Client’s request, the User’s email address, identity, job title and role are provided by that Client.
• From a User: the email address of a person invited to join the Client or to view a Mission.
• From services connected by the User: the email address of the Google account, calendar events and messages read on request; balances and transactions of connected bank or financial accounts.
• From public sources: information consulted online by the Virtual Collaborators during a Mission.

2.4 Client Content

Client Content includes in particular Mission requests, documents entrusted, messages and attachments in the team messaging, department content (decisions, commitments, contacts, deals, documents, bank transactions, invoices), scheduled Missions and Outputs.

The Client alone decides what data it includes. This data may concern third parties within the meaning of Article 1.5.

2.5 Special categories of data

Growthwing does not ask for any data falling within the special categories (such as origin, opinions, health, sexual orientation, biometric or genetic data) or any data relating to criminal offences. The Client refrains from including such data in Client Content, unless a legal basis and a genuine need justify it, under its own responsibility.

The Service is not certified for hosting health data within the meaning of Article L. 1111-8 of the French Public Health Code. A Client who practises a health profession, or whose activity leads them to collect health data about their patients or clients, does not include any such data in it (Article 6.2 of the Terms).

Voice is not processed for the purpose of identifying the person (Article 4.6).

2.6 Mandatory data

The email address, first name, surname, job title (except for a self-employed professional) and password are required to create the Account. Without them, the Account cannot be created.

In the website’s forms, mandatory fields are marked as such. Without them, the request cannot be processed.

All other data is optional. Its absence may limit the features available, in particular the relevance of the teams put together.

3.1 Legal bases

Each processing operation relies on one of the bases provided for in Article 6(1) of Regulation (EU) 2016/679 (the “GDPR”):

• performance of the contract concluded with the person, or of pre-contractual measures taken at their request (point (b));
• Growthwing’s legitimate interest, described for each processing operation, with due regard for the rights of the person, who may object to it (point (f) and Article 7.1);
• the consent of the person, which they may withdraw at any time (point (a) and Article 7.4);
• compliance with a legal obligation (point (c)), for retention and disclosures required by law (Articles 3.5 and 5.7).

The data retained by Growthwing is hosted on its server, rented from the host named in the annex. The tables below do not repeat this recipient.

3.2 Processing for which Growthwing is the controller

By sending an invitation request, the person agrees that Growthwing may contact them again about their request, early access and Growthwing’s offering, by email, by telephone or on WhatsApp, using the contact details they have provided. They may object at any time by writing to talk@growthwing.ai or by replying to the message received.

3.3 Processing carried out on behalf of the Client

For this processing, the legal basis is a matter for the Client, as controller. Growthwing acts on its instructions, which result from the use of the Service by its Users.

3.4 Account closure and deletion

Deletion of the Account may be requested from within the Service by a self-employed professional, or by the primary administrator where they are the Client’s only User. In other cases, the primary administrator first hands over their role or removes the other Accounts. Any other User sends their request to the Client’s administrator or to talk@growthwing.ai.

The request closes the Account immediately. The data is deleted after a period of thirty days. Logging in again during that period cancels the request.

When the period ends, the Account and Client data is deleted from the database. End-to-end encrypted files are not erased one by one: they are made permanently unreadable by destroying the keys that made it possible to decrypt them.

Files produced by Missions and saved on the Execution Engine machine (Article 4.8) follow a separate rule. Until the Service is opened to people outside Growthwing, they are not deleted automatically when the period ends. From that opening onwards, they are deleted within the same thirty-day period.

Where the Client still has other Users, the deleted Account is erased only after the keys it alone holds have been handed over. Its Missions remain with the Client; its name is replaced in them by the words “Deleted account”. Client Content may nevertheless continue to mention it. An encrypted space whose key is no longer held by any User is not erased: it remains attached to the Client.

Where Growthwing archives a Client, all its Accounts are deactivated and its data is deleted thirty days later, unless the archiving is cancelled within that period.

Technical copies of the database made in the thirty days before deletion keep the data until their own expiry (Article 3.2).

Data sent to the model providers and to the voice provider is retained by them under their own terms.

3.5 Retention required by law and exceptions

The periods above may be extended where the law requires it or where the data is needed to establish, exercise or defend legal claims. The data concerned is then isolated, access to it is restricted and it is deleted when the applicable period expires.

4.1 The Virtual Collaborators are artificial intelligence systems

The Virtual Collaborators are not people. Their first names and portraits are fictitious. Any interaction with them is an interaction with an artificial intelligence system.

The portraits are generated from a style template and a fictitious first name. No User data is sent for this purpose.

4.2 Who processes what

• Carrying out Missions: the Execution Engine puts the Virtual Collaborators to work using artificial intelligence models from providers established in particular in the United States. It receives the request, the context described in Article 3.3, the documents entrusted, the content read during the Mission and the search results.
• Assistance tasks: the Service entrusts certain tasks to model providers: titles, suggestions, rewording of requests, daily focus, profiles, labels and names of teams, deliverable reading pages, department Mission instructions. These tasks are entrusted to Mistral AI (Article 4.4).
• Voice: the voice provider conducts the spoken welcome interview and reads the deliverable presentations.
• Portraits: an image generation provider produces the portraits, without any User data.

Growthwing decides which provider is used for each task; the User does not choose. The providers, their location and the applicable safeguards are listed in the annex.

4.3 Tasks reserved for providers established in the European Union

The four assistance tasks that directly receive what the person says about themselves during the written interviews are entrusted only to providers established in the European Union: conducting the written team composition interview, summarising the welcome interview, summarising a new team and choosing a team’s name.

If none of these providers responds, the task fails. It is not passed to another provider.

This rule does not cover subsequent uses of the welcome interview summary. Growthwing sends this summary, under its own responsibility, with each Mission to the Execution Engine and the models it uses, which are processed in the United States (Article 6). It is also used to write the profiles of the Virtual Collaborators, a task entrusted to Mistral AI (Article 4.4).

The spoken interview is covered by Article 4.6.

4.4 Provider of the assistance tasks

The assistance tasks are entrusted to Mistral AI, a company established in France, which hosts the data in the European Union.

Growthwing may add or replace a provider under the conditions of Article 9 of this Policy and Article 6 of Annex 1 to the Terms.

4.5 No training

Growthwing does not use the data of Clients and Users to train any artificial intelligence model.

The exclusion of training is one of the commitments required of the Execution Engine provider for the models it uses. With Mistral AI and ElevenLabs, whose terms provide for such use unless it is refused, Growthwing has exercised that refusal.

4.6 Spoken interview

The welcome interview is conducted by voice. Team composition interviews may also be conducted in writing, where the Service offers it.

By voice, the User talks to a conversational voice system operated by ElevenLabs (Eleven Labs Inc.), established in the United States. The User’s browser sends their voice directly to this provider, in real time. The settings chosen by Growthwing ask the provider not to retain the audio recording and to limit retention of the transcript to one day.

This system is driven by a language model selected in the provider’s configuration. The rule in Article 4.3 does not apply to the spoken interview.

Growthwing does not process the voice to identify the person. As part of its service, the provider may produce conversation analysis indicators, in particular on sentiment. These indicators are not sent to Growthwing and are not used for any decision.

At the end of the interview, a model established in the European Union produces its summary, under the conditions of Article 4.3.

A User who does not wish their voice to be sent to this provider may contact talk@growthwing.ai before the welcome interview, and choose writing for the team composition interviews that offer it.

4.7 Automated decisions and profiling

Growthwing does not take any decision producing legal effects concerning a person, or similarly significantly affecting them, based solely on automated processing. It carries out no profiling for advertising purposes.

The Virtual Collaborators carry out Users’ instructions. They draft, analyse, summarise and propose. In the Sales department, they may rank the Client’s contacts and propose follow-ups. In the departments, they may propose actions.

These proposals are submitted to the User, who accepts or rejects them, except for actions that the autonomy levels set by the Client, by department and by type of action, allow without prior approval. Transfer orders require two human approvals and are never triggered by the Execution Engine or by a model.

The Virtual Collaborators are not designed to screen job applications, assess employees or evaluate a person’s solvency. The Client undertakes not to use them for these purposes, without Growthwing’s prior written consent (Article 6.2 of the Terms).

4.8 Three levels of content protection

4.8.1 Sealed Content

The following items are end-to-end encrypted: the body of team messages and their attachments; titles, summaries, reading pages and logs of Missions; deliverables; files of the spoken presentations.

The decryption keys are held only by authorised Users, protected by their passphrase. Growthwing holds none of these keys and cannot read this content.

When a User is invited, the key intended for them passes through Growthwing’s server for the duration of the invitation. Frozen copies shared by public link follow Article 5.3: they are encrypted with a key that appears only in the full address of the link, and Growthwing cannot read them.

4.8.2 Plaintext data

The following data is not end-to-end encrypted and can be read by Growthwing’s server:

• Account and authentication data, logs and metadata;
• the instruction and label of scheduled Missions;
• the welcome interview summary;
• the profiles of the Virtual Collaborators, team names, labels and channel names;
• the author, channel, timestamp and mentions of messages, as well as the existence of attachments;
• the email signature;
• profile photographs, logos and portraits, which are accessible to anyone who has their address.

4.8.3 Plaintext processing

To carry out a Mission or an assistance task, the content needed is processed in plaintext, as a technical necessity, by the Execution Engine and by the model called upon, for the purposes of the processing. It is then retained by the model provider under its own terms (Article 3.4).

End-to-end encryption protects Sealed Content at rest, in the database and file storage of the Service, and in transit between Users. It does not apply during this processing.

Files produced during a Mission (teams, work in progress, deliverables) are also saved on the Execution Engine machine, on Growthwing’s server. There, they do not benefit from end-to-end encryption and remain until they are deleted (Article 3.4). The staff console gives no access to these files; only a technical intervention on that machine allows such access, by Growthwing or by the Execution Engine provider, which administers it for the operation of the engine.

A User who loses their passphrase and access to all their devices can have their keys handed back to them by their administrator. A sole administrator, or a self-employed professional, in this situation loses access to the Client’s Sealed Content. Growthwing cannot restore it to them.

4.9 Security measures

Growthwing implements technical and organisational measures appropriate to the risk, including:

• two-factor authentication, which the Client’s administrator may require for all its Users where the Client is not a self-employed professional, and which is mandatory for Growthwing staff;
• end-to-end encryption of Sealed Content;
• encryption, with a key held by the server, of access authorisations for connected services, bank access keys and authentication secrets;
• encryption of communications and encryption of the database at rest;
• segregation of each Client’s data and verification of the User’s membership on every request;
• administration over a private network and logging of staff actions;
• rate limiting on public forms and blocking after repeated failed login attempts;
• exclusion of Client Content from the Service’s technical logs;
• support access to a User’s space on their authorisation only, after a fresh verification of the staff member’s identity, within the limits and with the log described in Article 4.11;
• internal security reviews.

No measure eliminates all risk. Growthwing holds no security certification.

4.10 Personal data breach

In the event of a personal data breach for which it is the controller, Growthwing notifies the Commission nationale de l’informatique et des libertés (CNIL) without undue delay and, where feasible, no later than seventy-two hours after becoming aware of it. This notification is not required if the breach is unlikely to result in a risk to the rights and freedoms of individuals.

Where the breach is likely to result in a high risk, Growthwing informs the data subjects without undue delay.

Where the breach affects Client Content, Growthwing informs the Client under the conditions of Annex 1 to the Terms, so that the Client can meet its own obligations.

4.11 Support access to a User’s space

Authorisation. The staff in charge of support access a User’s space only with their authorisation, which is optional, given for a support request (Article 4.10 of the Terms). The authorisation lasts until the request is resolved, and seven days at most. The User may end it at any time; any access in progress then stops.

Opening. Each opening requires a recent verification of the staff member’s identity, with their passkey or their second factor. This verification lasts one hour at most and must be done again as soon as the staff tool is closed and reopened. The opening creates a one-hour session, which may be extended within the limits of the authorisation. During the session, the User sees a banner naming the staff member by their first name.

How it works. The staff receive no image or video of the User’s screen. They open their own copy of the User’s space, loaded from Growthwing’s server with the User’s rights, in the company and the project of the request, without being able to change them, and within the limits below. The two copies are kept in step by exchanging the page viewed, the scrolling, the position of the pointers, the opening of menus and the text typed before it is saved. These exchanges are not kept. Only the User’s space in the Service is concerned: neither the device’s other tabs or applications, nor system windows (file selection, browser alerts). The staff member may follow the User’s page or leave it to view another page of the space, within the same limits. Each of them may point out a spot on the screen to the other.

Never transmitted. Passwords, verification codes, the passphrase, text typed in a Mission, a team or a conversation, and anything typed on a page closed to the staff are not transmitted to the other copy, which displays “Private input”.

Locked content and masked data. Sealed Content remains unreadable to the staff, who do not hold its keys. The following are not disclosed to them: the content of Missions and their deliverables, including the names of their attachments and the names of scheduled Missions, team messaging, the calendar, the connected mailbox, all department content (board, opinions, decisions, documents, deals, finances, department missions), documents, the vault, the treasury and payments, as well as the security and Account settings. The Service displays “You are not authorised to see this content” or a “Private content” screen, and these pages do not open from the staff’s copy. Email addresses, telephone numbers, bank details and postal addresses are masked.

Saving. On their own, the staff save only the User’s notification preferences. A closed list of other changes (the name and tags of a team; the company’s Desk team; the first name, last name and job title of the profile) is saved only with the User’s approval: the Service shows them exactly what will be saved, and the team concerned, and they approve or refuse. An approval is valid for that single change, exactly as shown, once. Without an answer within two minutes, nothing is saved. The User may also approve the changes on this list automatically for fifteen minutes, no later than the end of the session, and return at any time to approving each change. Any other change is refused to the staff, even if approved, in particular the actions reserved to the User (Article 4.10 of the Terms). Approval requests, which contain the values to be saved, are deleted after one day.

Log and summary. Each access, each page viewed, each approval request and its decision, and each action, taken or refused, is entered in the access log, which the User can consult in their security settings (Article 3.2). At the end of each session, a summary (duration, pages viewed, changes saved and refused, without their content) is added to the support request.

Growthwing does not sell or rent any personal data.

5.1 Growthwing staff

Authorised staff access plaintext data within the limits of their duties: Accounts, Clients, access requests, team profiles and names, the welcome interview summary, scheduled Missions, metadata. Of a Mission, they see only its identifier and its status. Every staff action is logged. The staff in charge of support see a User’s space only with their authorisation, under the conditions of Article 4.11.

5.2 Client Users

The Client’s administrators have access to the Accounts of its Users. Each User has access to the content open to them according to their role, their department and the visibility chosen by the author of a Mission: the author alone, their department or the whole Client. The Missions of a self-employed professional are visible to them alone, unless they share them under the conditions of Article 5.3.

5.3 People with whom the User shares content

The User may invite a person to view a Mission. They may also create a public link to a frozen copy of the Mission, with or without its deliverables. Anyone who holds this link can read this copy, without an Account. People’s names are removed from it, the copy expires after thirty days by default and the User can revoke the link at any time.

Emails sent from the connected Google mailbox are received by their recipients.

5.4 Growthwing’s processors

Growthwing uses processors, listed in the annex. Each receives only the data needed for its service. Growthwing binds them by a contract containing the commitments required by the GDPR, or accepts the contractual terms these providers offer.

5.5 Services connected by the User

5.5.1 Google

The User may connect their Google calendar and mailbox. Until Google has verified Growthwing’s application, this connection is open only to test accounts designated by Growthwing.

Depending on the features the User enables, the authorisation requested covers reading and creating calendar events, reading, modifying and sending messages, and the identity and email address of the account. It includes offline access on the User’s behalf. Access authorisations are stored encrypted.

This data is used exclusively to provide the User with the features they use: displaying and creating events; reading, sorting, drafting and sending messages; enabling the Virtual Collaborators to carry out the Missions that require it; for Users who have enabled it, allowing reading by the Sales department.

For carrying out Missions, this data is sent to the Execution Engine and the models it uses, under the conditions of Article 4.2.

The use and transfer of information received from Google APIs complies with the “Google API Services User Data Policy” and the “Google Workspace user data and developer policy”, including their Limited Use requirements.

This information is not sold, not used for advertising purposes, and not used to create, train or improve any artificial intelligence model.

It is shared with third parties only to the extent necessary to provide the features used by the User, to comply with the law or for security purposes. Growthwing staff do not read it, except with the User’s express consent, for security reasons or under a legal obligation.

The User may withdraw this access at any time from the Service’s Calendar page or from their Google account.

5.5.2 Banking and financial services

Where these features are enabled, the User may connect accounts held with Qonto, Wise, Pennylane or Payfit, using access keys that the User provides and that Growthwing stores encrypted. The Service uses them to read balances and transactions; the scope of access depends on the rights attached to the keys provided.

The User may also issue transfer orders through Qonto, subject to two human approvals. These services are chosen by the Client, which is their direct user.

5.6 Web browsing and calls

During a Mission, the Virtual Collaborators may consult websites. The operators of these websites and of search engines receive the corresponding queries, which may include elements of the request.

Connecting calls and rooms between Users relies on public Google servers, which receive the participants’ IP addresses in the process. The exchanges themselves travel directly between the participants.

5.7 Authorities

Growthwing discloses data to administrative or judicial authorities where required to do so by law.

Some recipients process data outside the European Union. The table below shows, for each destination, the recipients, the data and the mechanism governing the transfer within the meaning of Articles 44 to 46 of the GDPR.

Mistral AI hosts the data in the European Union. Under its terms, its own sub-processors established outside the Union may receive data temporarily, under an adequacy decision or standard contractual clauses.

Queries made while browsing the web during a Mission (Article 5.6) may reach websites located outside the Union, without any particular safeguard.

Exchanges with the Google account that the User connects (Article 5.5) fall within the terms the User has agreed with Google.

A copy of the safeguards mentioned above can be obtained by writing to talk@growthwing.ai.

7.1 Rights

Under the conditions laid down by the GDPR, everyone has:

• the right to access their data and to obtain a copy of it;
• the right to have inaccurate or incomplete data rectified;
• the right to erasure;
• the right to restriction of processing;
• the right to portability of the data they have provided, where the processing is based on the contract or on consent;
• the right to object, on grounds relating to their particular situation, to processing based on legitimate interest;
• the right to withdraw their consent at any time.

They may also set instructions on the retention, erasure and disclosure of their data after their death, in accordance with Article 85 of French Law no. 78-17 of 6 January 1978.

7.2 Exercising rights

Requests should be sent to talk@growthwing.ai. Growthwing responds within one month of receipt. This period may be extended by two months, taking into account the complexity or number of requests; the person is then informed within the first month.

Growthwing may ask for proof of identity where it has reasonable doubts about the identity of the person making the request. Exercising these rights is free of charge, except for manifestly unfounded or excessive requests.

Erasure may be refused where retention is required by law or is necessary to establish, exercise or defend legal claims.

7.3 Data processed on behalf of Clients

For Client Content, including the data of the third parties mentioned in Article 1.5, the Client is the controller. It is for the Client to inform those people and to respond to their requests.

A request of this kind received by Growthwing is forwarded to the Client, which is given assistance in responding to it, under the conditions of Annex 1 to the Terms.

7.4 Withdrawing consent

The person may withdraw their consent to audience measurement at any time, using the “Cookies” link in the website footer. Withdrawing is as easy as accepting. It does not affect the lawfulness of the processing carried out before the withdrawal.

7.5 Complaint to the CNIL

Anyone may lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL), on its website www.cnil.fr, or with the supervisory authority of the Member State of their habitual residence, place of work or place of the alleged infringement.

8.1 Principle

Until the visitor’s choice has been obtained, no tracker requiring consent is placed on or read from the visitor’s device.

The fonts of the website and the application are loaded from Google’s servers (Google Fonts), which receive the visitor’s IP address in the process. No tracker is placed for this purpose.

8.2 Trackers needed for the Service to work

These trackers are strictly necessary to provide the Service requested by the person. They are therefore not subject to the person’s consent, in accordance with Article 82 of French Law no. 78-17 of 6 January 1978 on information technology, data files and civil liberties.

8.3 Audience measurement

When the visitor clicks “Accept”, the website loads the Google Analytics tool, which places cookies to measure traffic. Google’s consent mode is set to refuse all storage and all use for advertising purposes. The IP address is truncated.

If the visitor does not accept, the tool is not loaded.

8.4 Managing the choice

The banner lets the visitor accept or refuse with equal ease. The choice can be changed at any time, under the conditions of Article 7.4.

Growthwing may amend this Policy, in particular to reflect a change in the Service, in a provider or in the regulations. The version in force is published on the website with its date.

Any substantial change is brought to the attention of Users by email or within the Service at least thirty days before it comes into force. Where a change requires the person’s consent, Growthwing obtains it beforehand.

List in force at the date of this Policy. Transfers outside the Union are detailed in Article 6.

This list does not include the services that the User connects themselves (Article 5.5), nor the websites consulted during a Mission (Article 5.6).