Effective Date: January 1, 2025
GrowthSpan Inc. ("GrowthSpan", "we", "our", or "us") is committed to protecting the privacy and personal information of our clients, users of our website (www.growthspan.ca), and authorized users of our software platform (GrowBase™). This Privacy Policy outlines how we collect, use, disclose, and protect personal information in accordance with Canadian and U.S. privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable federal and provincial/state laws. This policy applies to:
- Visitors to our website;
- Clients who engage us for consulting services;
- Authorized users of our platform (e.g. employees and staff of our clients);
- Individuals whose information is processed on behalf of our clients.
1. Roles and Responsibilities
- GrowthSpan is a data controller for personal data collected on our website and during direct business interactions.
- GrowthSpan is a data processor for personal information handled through the Grow/Base™ platform on behalf of our clients. Our clients are responsible for ensuring that they have the necessary permissions and consents to provide personal information to us for processing.
2. Information We Collect
We collect and process the following types of personal information:
- Client & User Information: Name, email address, phone number, business address, company/organization details.
- Platform Data (on behalf of clients):
- Identifying details: Full name, contact information, property transaction details.
- Sensitive identifiers: Social Insurance Number (SIN), HST numbers, government-issued IDs (e.g. driver’s license).
- Uploaded documents: Personal ID forms and supporting documentation.
- Website Usage Data: IP address, browser type, device information, and pages visited (via Google Analytics).
- Platform Interaction Data (planned): Usage logs and session recordings via FullStory (used to improve user experience).
3. How We Use Personal Information
We use personal information to:
- Deliver consulting services to clients;
- Provide access to and maintain the Grow/Base™ platform;
- Facilitate intake, onboarding, and lead conversion processes for clients;
- Improve functionality and usability of our platform;
- Respond to inquiries and support requests;
- Comply with legal and regulatory obligations. We do not sell or rent personal information.
4. Legal Basis for Processing
We rely on:
- Consent obtained by our clients or directly through our website;
- Contractual necessity (e.g., service agreements);
- Compliance with legal obligations;
- Legitimate interests, such as improving our platform.
5. Data Storage & Security
- GrowthSpan uses third-party cloud service providers to host and store all data.
- Temporary data such as uploaded IDs or forms are securely deleted or transferred to clients promptly.
- We implement reasonable administrative, technical, and physical safeguards to protect data.
6. Sharing of Personal Information
We may share information with:
- Our service providers (e.g., cloud hosting, analytics platforms) under strict confidentiality agreements;
- Clients, for whom we act as a processor, and only under their instruction;
- Legal or regulatory authorities when required by law.
7. Data Subject Rights
Individuals may have the right to:
- Access their personal information;
- Correct inaccurate information;
- Withdraw consent (where applicable);
- Request deletion, subject to contractual and legal limitations. Requests can be submitted via: hello@growthspan.ca
8. Cookies and Tracking Technologies
- Our website uses Google Analytics to collect anonymized usage data.
- The GrowBase™ platform will use FullStory to analyze user interactions.
- Users may disable cookies via their browser settings or opt-out using available tools.
9. Data Retention
We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by law. Temporary files (e.g., uploaded IDs) are deleted after transfer to clients.
10. International Data Transfers
Our service providers may process or store data outside of Canada. In such cases, data is subject to the laws of the hosting jurisdiction. We ensure contractual protections are in place to safeguard transferred data.
11. Policy Updates
We may update this Privacy Policy periodically. Updates will be posted on our website with a revised effective date.
12. Contact Us
For questions, requests, or concerns about this Privacy Policy, contact:
GrowthSpan Inc.
Email: hello@growthspan.ca
Website: www.growthspan.ca