Privacy Policy

Last updated: 25 May 2026

1. Who we are

This Privacy Policy describes how GrowthPlan OÜ ("GrowthPlan," "we," "us," or "our") collects, uses, and protects your personal data when you visit growthplan.agency, contact us, or use our services.

Data controller:

GrowthPlan OÜ

Registry code: A 50312144

Registered address: Tartu mnt 67/1-13b, Tallinn 10115, Estonia

Email: e.novikova@growthplan.agency

Phone: +380 99 722 2199

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act.

2. Information we collect

2.1 Information you provide directly

Contact and lead form data: name, email address, company name, role, website, message content, and any other information you submit through forms on our website or in communications with us.
Client project data: brand guidelines, product information, scripts, briefs, raw footage, creator/talent releases, and other creative assets provided for the production of ad creatives.
Billing information: company name, billing address, VAT number, payment account details, and invoice data.

2.2 Information collected automatically

When you visit growthplan.agency, we automatically collect:

IP address and approximate location
Browser type and version, device type, operating system
Pages visited, time spent, referring URL, click and scroll data
Cookie and pixel identifiers (see Section 4)

We collect this data using tools including Google Analytics, Meta Pixel, and similar analytics technologies.

3. How we use your information and legal bases

Purpose	Legal basis (GDPR Art. 6)
Responding to inquiries submitted through contact forms	Legitimate interest (Art. 6(1)(f)) / pre-contractual steps (Art. 6(1)(b))
Providing video ad production services to clients	Performance of a contract (Art. 6(1)(b))
Processing payments and issuing invoices	Performance of a contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c))
Website analytics and performance measurement	Consent (Art. 6(1)(a))
Advertising, retargeting, and measurement via Meta Pixel and similar tools	Consent (Art. 6(1)(a))
Complying with tax, accounting, and legal obligations	Legal obligation (Art. 6(1)(c))
Protecting our legal rights and preventing fraud	Legitimate interest (Art. 6(1)(f))

4. Cookies and tracking technologies

We use cookies, pixels, and similar technologies to:

Operate essential website functions (strictly necessary cookies)
Measure how visitors interact with our site (analytics cookies)
Deliver and measure advertising effectiveness (marketing cookies)

Non-essential cookies are only set after you provide consent through our cookie banner. You can withdraw consent at any time via the cookie settings on our website or by adjusting your browser settings.

Current third-party cookie and pixel providers:

Google LLC (Google Analytics)
Meta Platforms, Inc. (Meta Pixel)

5. Sharing your information

We do not sell your personal data. We share data only with:

Service providers (processors) acting on our behalf — including website hosting, analytics, payment processing, CRM, and email providers — all bound by data processing agreements.
Clients — when you work with us as part of a client's team, we may share relevant project contact information with that client.
Authorities — when required by law, court order, or to defend our legal rights.

Current categories of subprocessors include: website hosting (Webflow), email and productivity (Google Workspace), analytics (Google, Meta), accounting and payment processing, and AI/creative production tools used in our workflow.

6. International data transfers

Some of our service providers and clients are located outside the European Economic Area (EEA), primarily in the United States. When we transfer personal data outside the EEA, we rely on appropriate safeguards under GDPR, including:

Standard Contractual Clauses (SCCs) approved by the European Commission
The EU-US Data Privacy Framework, where applicable

7. Data retention

We retain personal data only as long as necessary for the purposes set out above:

Contact/lead form data: up to 24 months from last contact, unless we enter a business relationship
Client project data and footage: for the duration of the engagement plus up to 3 years for portfolio and reference purposes, unless otherwise agreed in writing
Billing and accounting records: 7 years (Estonian Accounting Act)
Website analytics data: in line with the retention settings of our analytics tools (typically up to 26 months)

8. Your rights

Under the GDPR, you have the right to:

Access — request a copy of the personal data we hold about you
Rectification — correct inaccurate or incomplete data
Erasure — request deletion of your data
Restriction — limit how we process your data
Portability — receive your data in a structured, machine-readable format
Object — to processing based on legitimate interest or for direct marketing
Withdraw consent — at any time where processing is based on consent
Lodge a complaint with a supervisory authority. The Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) can be reached at info@aki.ee or www.aki.ee.

To exercise your rights, contact us at e.novikova@growthplan.agency. We respond within 30 days.

9. Data security

We implement appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS), access controls, secure cloud storage, and ongoing security review of our tools and subprocessors.

10. Children's privacy

Our services are not directed at individuals under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date above reflects the most recent revision. Material changes will be communicated on our website.

12. Contact us

For any questions, requests, or complaints regarding your personal data:

GrowthPlan OÜ

Email: e.novikova@growthplan.agency

Phone: +380 99 722 2199

Address: Tartu mnt 67/1-13b, Tallinn 10115, Estonia