xGrowth Privacy Policy

Introduction

Last Updated: April 24, 2025

xGrowth (“we,” “our,” or “us”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our AI training services, website, applications, and other digital products (collectively, the “Services”).

We provide AI-powered business growth solutions, including AI training services, digital presence development, customer acquisition systems, business operations management, and business intelligence services. Due to the nature of our Services, we process various types of personal data in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and other relevant privacy regulations.

Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it. By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

Scope

This Privacy Policy applies to:

  • Visitors to our website and users of our digital platforms

  • Clients and customers who purchase or use our Services

  • Participants in our AI training programs (both individual learners and corporate training participants)

  • Business partners, vendors, and suppliers

  • Job applicants and employees

  • Data processed through our AI systems and applications

This Privacy Policy does not apply to information collected by third parties, including any websites, services, or applications that may link to or be accessible from our Services, unless explicitly stated.

Data Controller Information

xGrowth is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or our data practices, please contact us at:

xGrowth
Rua da Tapada 215
Porto
Portugal

Email: privacy@xgrowth.com
Phone: +351 916 247 032

Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds:

  • Consent: When you have given clear consent for us to process your personal data for a specific purpose

  • Contract: When processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract

  • Legal Obligation: When processing is necessary for compliance with a legal obligation

  • Legitimate Interests: When processing is necessary for our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms

Personal Data We Collect

Information You Provide to Us:

  • Identity and Contact Information: Name, email address, postal address, phone number, job title, company name

  • Account Information: Username, password, account preferences

  • Financial Information: Payment details, billing address, transaction history

  • Profile Information: Professional background, skills, interests, preferences

  • Training Data: Course selections, progress, assessment results, certifications

  • Communications: Messages, emails, feedback, survey responses

  • User Content: Materials you upload, share, or create while using our Services

Information We Collect Automatically:

  • Device Information: IP address, browser type, operating system, device identifiers

  • Usage Data: Pages visited, features used, time spent, clicks, interactions

  • Location Data: General location based on IP address

  • Log Data: Access times, error reports, hardware and software information

  • Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar tracking technologies

Information from Third Parties:

  • Business partners and service providers

  • Identity verification services

  • Marketing and analytics providers

  • Publicly available sources

  • Social media platforms (if you connect your account)

  • Your employer (if enrolled in corporate training)

How We Use Your Personal Data

Providing and Managing Our Services:

  • To deliver the Services you have requested or purchased

  • To create and manage your account

  • To personalize your experience and provide tailored content

  • To process payments and maintain billing records

  • To track your progress in training programs

  • To issue certificates and credentials

Improving and Developing Our Services:

  • To analyze usage patterns and trends

  • To test and improve features and functionality

  • To develop new products and services

  • To conduct research and analytics

  • To enhance user experience and interface design

Communication and Support:

  • To respond to your inquiries and provide customer support

  • To send administrative notifications and service updates

  • To provide information about products, services, and events

  • To conduct surveys and collect feedback

  • To maintain our business relationship

AI Training and Development:

  • To train and improve our AI models and algorithms

  • To develop industry-specific AI solutions

  • To enhance predictive capabilities and recommendations

  • To improve natural language processing and understanding

Legal and Security Purposes:

  • To verify your identity and prevent fraud

  • To protect the security and integrity of our Services

  • To enforce our terms of service and other policies

  • To comply with legal obligations and respond to legal requests

  • To establish, exercise, or defend legal claims

Data Sharing and Disclosure

We may share your personal data with:

Service Providers and Business Partners:

  • Cloud hosting and storage providers

  • Payment processors and financial institutions

  • Customer support and communication platforms

  • Analytics and marketing service providers

  • Learning management system providers

  • Professional advisors and consultants

Corporate Clients:

  • If you participate in corporate training, we may share your progress and results with your employer

Business Transfers:

  • In case of mergers, acquisitions, or similar events, your data may be transferred

Legal Requirements:

  • To comply with the law or legal processes

  • To protect rights, safety, or prevent fraud

  • We do not sell your personal data

International Data Transfers

Your data may be transferred to countries outside your own. We apply GDPR safeguards such as:

  • Standard Contractual Clauses

  • Binding Corporate Rules

  • Adequacy decisions

  • Legal derogations when necessary

Data Retention

We keep your data as long as needed for the purposes described, or as required by law. After that, we delete or anonymize it.

Your Data Protection Rights

Depending on where you live, you may have rights such as:

  • Access, correction, deletion

  • Restriction or objection to processing

  • Data portability

  • Withdraw consent

  • Lodge a complaint with a supervisory authority

Data Security

We use encryption, access control, security training, and backups to protect your data. No system is 100% secure, but we take all reasonable precautions.

Cookies and Similar Technologies

We use:

  • Essential cookies

  • Functional cookies

  • Analytics cookies

  • Marketing cookies

You can manage cookies in your browser settings. Some features may not work if disabled.

Children’s Privacy

Our Services are not directed to children under 16. We do not knowingly collect their data. Contact us if you believe a child has shared data with us.

Changes to This Policy

We may update this policy. The date at the top shows the latest version. Continued use of our Services means you accept the changes.

Contact Us

xGrowth
Rua da Tapada 215
Porto
Portugal
Email: privacy@xgrowth.com
Phone: +351 916 247 032

Data Protection Officer:
Fernando Castro
dpo@xgrowth.com

If unresolved, you may contact the Portuguese Data Protection Authority (CNPD).

Specific Provisions for AI Training Services

AI Training Data:

  • We collect interaction data with AI tools

  • Data may be used to improve models

  • We minimize personal data use and apply anonymization when possible

AI Decision-Making:

  • We inform you about automated processing

  • You can request human review or contest decisions

  • We regularly test our models for bias

AI Ethics and Governance:

  • We follow ethical AI principles

  • We assess risk and maintain transparency

  • Human oversight is always involved

Acknowledgment

By using our Services, you acknowledge and agree to this Privacy Policy.