Privacy Policy

GrowthHero Privacy Policy based on article 13 and 14 of GDPR

SureSwift Capital, Inc. (“GrowthHero” or “us”, “our”, “we”) provides online solution which enables to build, manage, and optimize partner programs on Ecommerce platforms (the “Service”). During provision of Services we collect and process some personal data regarding employees of users of our Services (“You” or “your”). 

In this Privacy Policy we describe how we collect and use your personal data and rights and options available to you with respect to your personal data.

Please note that this Policy covers our role only with respect to personal data for which we are “data controller” within the meaning of Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation “GDRP”).

Who controls your data? 

Your personal data controller, i.e. the entity who is responsible for your personal data, is of GrowthHero i.e. SureSwift Capital, Inc., 5201 Eden Ave, Suite 300, Edina, MN 55436 USA .

Who can you contact to get more information on how we process your personal information? 

If you have any question regarding your privacy, please write at the following e-mail address [email protected] or by traditional mail at the address: SureSwift Capital, Inc., 5201 Eden Ave, Suite 300, Edina, MN 55436 USA.

How we obtained your data? 

We may receive your personal data from the following sources: 

• directly from you in particular in direct communication;
• from users of our Services for which you work and which made your data available by authorizing you to use our Services panel;
• from Shopify, Inc. and other ecommerce platforms;
• from Google Analytics (Google).

What data about you we process? 

We process the following categories of your personal data: (i) name, surname and e-mail address, (ii) name of shop (organization) that uses our Services which granted you access to our Services panel. 

Why do we process your data? 

We process your personal data to provide Services to organization for which you work.

What is the legal basis to process your data? 

We process your personal data on the basis of Article 6 letter (f) of the GDRP i.e. processing is necessary for the purposes of the legitimate interests pursued by us, that is – provision of Services to users of our Services for which you work.

Am I obliged to provide my data?

Providing your personal data is necessary for us to provide the Services and allow you to access the Services panel.

What are your rights in regards of data processing? 

You may request us to exercise the following rights you have: to access, rectify and erase your data, limit its processing, transfer it, a right not to be a subject to automated decision – making, including profiling, and to object to the processing of your personal data. 

You may exercise these rights, when: 

• regarding right to rectify data – data is incorrect or incomplete; 
• regarding right to erasure of data – personal data are no longer necessary in relation to the purposes for which they were collected; you withdraw your consent on which the processing is based (in scope of this consent); you object to data processing; data has been processed unlawfully; data have to be erased for compliance with a legal obligation; 
•  regarding restriction of processing: data is incorrect – for a period enabling us to verify your data; data has been processed unlawfully, but you don’t want it to be removed; we no longer need your data, but you may need them for the exercise or defense of your legal claims; you object to processing data – until verification whether our legitimate grounds override the grounds of objection; 
• regarding right to transfer data: the processing is based on consent or on a contract and the processing is carried out by automated means. 

To the extent you gave us your consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal. 

Where do I complain about my data being processed?

You can lodge a complaint regarding processing of your personal data by us to your local data protection authority. To find your Data Protection Authority, please follow this link.

When you can object to processing of your data? 

You have the right to object to the processing of personal data when they are processed on a legitimate interest basis, and the objection is justified by your particular situation.

Do we share your personal data with other entities? 

We do not share your data with other entities. 

How long are we going to store your data? 

We are going to store your data as long as you are entitled by user of our Services to access the Services panel. 

Do we process your personal data automatically (including profiling) in a way that affects your rights? 

Your personal data will not be used for automated decision making, including profiling. By profiling, we mean the processing of your data by using them to evaluate certain information about you, in particular to analyze or forecast your personal preferences and interests.