Privacy Policy

1. Controller & Contact

The controller responsible for data processing described in this policy is:

As a small business, we are not required to appoint a Data Protection Officer under Art. 37 GDPR / § 38 BDSG. For any data protection inquiry, please contact us directly at the email above.

2. Overview of Processing

We process personal data when you visit our website, submit an application to work with us, book a call, or otherwise interact with our tools and campaigns. This includes data such as your name, email address, phone number, company name, website, and information you voluntarily provide about your business (e.g., revenue range, ad spend, business challenges).

Because our website relies on a number of third-party tools to operate (hosting, scheduling, forms, a CRM, and advertising platforms), this policy explains each one individually below so you know exactly what is used and why.

3. Legal Bases for Processing

Depending on the specific processing activity, we rely on the following legal bases under Art. 6(1) GDPR:

• Art. 6(1)(b) — processing necessary to take steps at your request prior to entering into a contract, or to perform a contract (e.g., processing your application, delivering Services to clients);
• Art. 6(1)(f) — processing necessary for our legitimate interests, such as operating and securing the website, basic analytics, and direct-response advertising, provided these interests are not overridden by your interests or fundamental rights;
• Art. 6(1)(a) — your consent, where required (e.g., for certain non-essential cookies or marketing communications), which you may withdraw at any time with effect for the future.

4. Hosting, CDN & Performance

Our website is hosted by WPX Hosting (WPX Ltd., Sofia, Bulgaria), which provides web hosting and its own content delivery network ("XDN") to serve our Site. When you visit our Site, WPX Hosting automatically processes technical data such as your IP address, browser type, referring page, date and time of access, and similar log data, in order to deliver the page reliably and protect against abuse. This processing is based on our legitimate interest (Art. 6(1)(f) GDPR) in providing a secure and reliable website. WPX Hosting is based in the European Union.

We may also draw on aggregated, anonymous web performance data such as the Chrome UX Report (CrUX), published by Google, to monitor and improve page loading speed. This dataset does not identify individual visitors.

5. Site Management

We use Google Search Console ("Google Webmaster Tools"), provided by Google Ireland Limited, to monitor our Site's presence in Google Search results, including aggregate data such as search queries, click-through rates, and indexing status. This data is generally aggregated and does not identify individual visitors. Processing is based on our legitimate interest in maintaining and improving the Site (Art. 6(1)(f) GDPR).

6. Cookies & Similar Technologies

Our Site and the third-party tools embedded in it may use cookies and similar technologies (such as pixels and local storage) to enable core functionality, remember preferences, measure usage, and support advertising as described in the sections below. Where a cookie is not strictly necessary for the Site to function, it is set only with your consent, where required under applicable law (e.g., the German TDDDG implementing the ePrivacy Directive). Embedded tools that may set cookies or similar technologies include Calendly (booking page), Wistia and Vimeo (video), Google Analytics, and the advertising platforms listed in the sections below.

7. Application Form & CRM

When you submit the application form on our demo page, we collect the information you provide — including your name, email, phone number, company website, monthly revenue range, ad spend range, and a description of your challenge — in order to evaluate your application and, if accepted, provide our Services (Art. 6(1)(b) GDPR).

This information is stored in our customer relationship management system, Close (operated by Elastic, Inc., dba Close, San Francisco, California, USA), which we use to manage applications, client communication, and the sales process. Close may process your data on servers located in the United States. Further information is available at close.com/privacy.

8. Lead Sourcing

To identify and source prospect contact data used in outreach campaigns, we use ListKit (ListKit, USA), a B2B contact data and lead-sourcing platform. ListKit provides verified business contact information (such as name, business email, job title, and company details) that we use to build and run campaigns on behalf of our clients.

The prospect data sourced through ListKit relates primarily to third-party business contacts rather than visitors to this Site. Where our Services involve processing such data on a client's behalf, this is governed by the applicable data processing agreement referenced in our Terms of Service. Further information on ListKit's own data practices is available on their website.

9. Our Own B2B Marketing Outreach

Separately from campaigns we run on behalf of clients, we also use B2B cold email ourselves to contact prospective clients about our own Services. If you received an email from us directly about Artificial Growth's own offering, this section explains why and what rights you have.

The business contact data we use for this purpose (such as your name, business email address, job title, and company) is sourced from providers such as ListKit, professional networks such as LinkedIn, and other publicly available business sources. We process this data based on our legitimate interest in marketing our services to other businesses (Art. 6(1)(f) GDPR), consistent with Recital 47 GDPR, which recognizes direct marketing as a legitimate interest, and with the conditions for permissible B2B outreach under § 7 of the German Act Against Unfair Competition (UWG) — in particular, that we only contact businesses where we reasonably assume an interest in our Services given their industry and profile, that every email clearly identifies us as the sender, and that an easy means of opting out is provided in every message.

You have the right to object to this processing at any time, without giving a reason (Art. 21(2) GDPR). You can do this by replying "unsubscribe" or similar to any email from us, using the opt-out link included in the message, or contacting us directly at info@artificialgrowth.io. Once you opt out, we will stop contacting you and retain your contact details only on a suppression list, for the sole purpose of ensuring we do not contact you again.

10. Scheduling Tools

To book and manage demo calls, we use Calendly (Calendly, LLC, Atlanta, Georgia, USA). When you book a call, Calendly processes the information you provide (name, email, phone number, selected time slot, and any answers to scheduling questions) in order to schedule and remind you of your appointment (Art. 6(1)(b) GDPR).

Our booking page at artificialgrowth.io/book-meeting embeds Calendly. When you load it, Calendly receives your IP address and may set cookies and similar technologies. Calendly displays its own cookie banner, and non-essential cookies are set only with your consent (Art. 6(1)(a) GDPR; § 25 TDDDG). You can withdraw your consent at any time via Calendly's cookie settings.

Further information: calendly.com/privacy.

11. Additional Forms

Where we use Typeform (Typeform S.L., Carrer Bac de Roda, Barcelona, Spain) for supplementary forms or surveys, Typeform processes the data you submit on our behalf in order to route it to us. Typeform is based in the EU; details are available at typeform.com privacy policy.

12. Billing & Invoicing

For clients, we use easybill (easybill GmbH, Berlin, Germany) to create and manage invoices. Where you become a client, easybill processes data such as your name, business address, and invoice line items in order to issue invoices and meet our statutory bookkeeping obligations (Art. 6(1)(b) and Art. 6(1)(c) GDPR, in conjunction with German commercial and tax law). easybill is based in Germany.

13. Video Hosting

Where we embed video content on the Site (such as our intro video), we may use Wistia (Wistia, Inc., Cambridge, Massachusetts, USA) and/or Vimeo (Vimeo.com, Inc., New York, USA) as video hosting providers. These providers may process technical data such as your IP address, device information, and viewing behavior in order to deliver and measure engagement with the video. Further information: wistia.com/privacy and vimeo.com/privacy.

14. Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (with data processing by Google LLC, USA), to understand how visitors use our Site (e.g., pages visited, session duration, traffic source). Google Analytics uses cookies and similar technologies and processes your IP address (which may be shortened/anonymized) and usage data.

This processing is based on your consent (Art. 6(1)(a) GDPR) where required, or our legitimate interest in understanding and improving our Site (Art. 6(1)(f) GDPR). You can opt out using the Google Analytics opt-out browser add-on. Further information: policies.google.com/privacy.

15. Advertising & Retargeting

We run advertising campaigns and, where you have interacted with our Site, may show you retargeted ads via the following platforms. Each platform may set its own cookies or use similar technologies (e.g., pixels, conversion tags) when you visit our Site, and may combine this data with information from your account on that platform if you have one.

This processing is based on your consent (Art. 6(1)(a) GDPR), obtained where required before non-essential advertising cookies are set. You can withdraw consent at any time, and can generally manage ad personalization directly within each platform's own account settings (e.g., Meta Ad Settings, Google Ads Settings).

16. Internal Communication

We use Slack (Slack Technologies, LLC, a Salesforce company, San Francisco, California, USA) internally to receive notifications about new applications and coordinate our own team's workflow. Where an application or booking notification is routed into Slack, the data it contains (e.g., your name and contact details) is processed within our internal workspace for this purpose (Art. 6(1)(f) GDPR).

17. International Data Transfers

Several of the providers listed above (including Close, ListKit, Calendly, Wistia, Vimeo, Meta, Google, LinkedIn, X, Outbrain, and Slack) are based in, or process data in, the United States. Our hosting provider, WPX Hosting, is based in the European Union. Where personal data is transferred outside the European Economic Area, we rely on appropriate safeguards recognized under Art. 44 et seq. GDPR, in particular: the provider's certification under the EU-U.S. Data Privacy Framework where applicable, and/or the Standard Contractual Clauses adopted by the European Commission pursuant to Art. 46(2)(c) GDPR, together with any supplementary measures required.

You can request further information about the specific safeguards applicable to a given provider by contacting us at info@artificialgrowth.io.

18. Storage Duration

We retain personal data only for as long as necessary for the purposes described in this policy, or as required by applicable law. Application and client data is generally retained for the duration of the business relationship plus applicable statutory retention periods under German commercial and tax law (typically six to ten years for business records, pursuant to §§ 147 AO / 257 HGB). Analytics and advertising data is retained according to each provider's own default retention settings, unless we configure a shorter period. Where you have unsuccessfully applied to work with us, we retain your application data for a reasonable period to evaluate future applications, unless you request earlier deletion.

19. Your Rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you (Art. 15);
• Rectify inaccurate or incomplete data (Art. 16);
• Erasure of your data, subject to legal retention obligations (Art. 17);
• Restrict processing under certain circumstances (Art. 18);
• Data portability for data you provided to us (Art. 20);
• Object to processing based on legitimate interests, including direct marketing (Art. 21 — see Section 17 below);
• Withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal (Art. 7(3));
• Lodge a complaint with a supervisory authority, in particular the data protection authority of Schleswig-Holstein (Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein, ULD) or your own EU member state authority.

To exercise any of these rights, contact us at info@artificialgrowth.io.

20. Right to Object

Where we process your data based on legitimate interests (Art. 6(1)(f) GDPR), you have the right to object at any time for reasons arising from your particular situation. Where your data is processed for direct marketing purposes, you have the right to object at any time without needing to provide a reason, including to any related profiling. To object, contact us at info@artificialgrowth.io.

21. Data Security

We implement technical and organizational measures appropriate to the risk to protect your data against unauthorized access, loss, or misuse, including the use of encrypted connections (TLS/SSL) for data transmitted through our Site. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

22. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, tools, or legal requirements. The current version is always available on this page, with the effective date shown at the top.