Privacy Policy and Disclaimer

Last updated: August 2, 2025

This Privacy Policy explains how we collect, use and protect your personal data when you access or use the Grow10x Service (https://grow10x.io/ and all related web features) (the “Service”). It forms part of the Terms of Use you accepted (the “Contract”).

This Privacy Policy is based on the provisions of the data protection laws applicable in your country of residence.

1. Controller

The “Controller” of your personal data under this Privacy Policy is the company that operates the Service pursuant to the Contract.

For complete information about the Controller’s identity, please see the Contract. In this Privacy Policy, we refer to each such company as “Grow10x,” “we,” or “us.”

If you have any questions about how we process your personal data under this Policy, you can contact us at:

E-mail: support@grow10x.io

If you reside in another jurisdiction, please consult the specific channels at the end of this Privacy Policy or contact the Data Protection Officer responsible for your jurisdiction.

2. Categories of Personal Data Processed

The following table outlines the categories of personal data we collect and process. We collect this information directly from you, the data subject.

Data subjectsCategoryDescription
UsersRegistration dataPersonal data we need to collect to create your Grow10x account. This information includes:
  • full name;
  • email;
  • phone number;
  • address;
  • age;
  • postal code;
  • other registration/authentication data.
StudentsStudent DataIf you decide to participate in a Grow10x course, we will likely need to receive some additional information about you. This may include:
  • information about your chosen courses;
  • your attendance and progress in courses;
  • course-related feedback;
  • payment status;
  • information about your work permit;
  • area of interest or profession;
  • professional status;
  • the highest degree or level of education and your field of study;
  • gender;
  • graduation status.
Users, students, website visitors, Grow10x event participantsOther DataBy using the Service or interacting with Grow10x's team or website, you may choose to provide us with certain personal data about yourself. In particular, this is the case when you contact the support team about various matters or subscribe to receive informational or promotional materials about the Service. For this, we may collect information about your name, and contact information. Please note that all these actions do not require registration.
Users, students, website visitorsCookieGrow10x uses cookies, including web beacons (aka “pixels”), and other tracking codes on the platform to improve the quality of your user experience (“Cookie”, or “Cookies”). A cookie is a small, very frequently used text file that the browser installs on your device when you visit a website and then sends information about your visit back to the website when you visit it again. Information collected by cookies may include browser information, Internet activity, and usage data. You can learn more about cookies in our Cookie Notice.
TutorsTutor DataGrow10x makes some information available about the tutors who participate in its educational courses. This information includes:
  • full name;
  • education level;
  • city of residence;
  • area of interest;
  • professional experience.
Graduating studentsStudent DataGrow10x may already have most of this information (or perhaps all), but some personal data may have changed and need to be updated etc).

3. Purposes and legal bases for the processing

We only process your data when we have one of the legal bases mentioned below:

3.1. Performance of the Contract

We may process your personal data to provide you with the Service in accordance with the Contract.

3.2. Legitimate Interest

We may process your personal data when we (or a third party) have a legitimate interest in using it in a certain way, provided that such processing is both necessary and balanced against any potential impact on your rights and freedoms. Where the data protection laws of your country of residence recognize “legitimate interests” as a lawful basis for processing, we rely on this legal basis to:

  • Enhance and personalize our Service;
  • Prevent and detect fraud;
  • Protect our legal rights and property;
  • Improve security and user experience.

If you reside in a jurisdiction that does not recognize “legitimate interests” as a valid legal basis, we will instead rely on any alternative legal bases provided under that country’s data protection laws.

3.3. Consent

When required by applicable law, we will process your personal data based on your consent. You may withdraw your consent at any time without affecting the lawfulness of any processing carried out before your withdrawal.

3.4. Legal or Regulatory Obligations

When we need to process your personal data to comply with applicable laws.

3.5. Summary of Purposes and Legal Bases

The table below defines the following:

  • Our purposes for processing your data;
  • The legal bases we rely on under applicable law;
  • The categories of personal data used for each purpose.
Purpose of the processing of your dataLegal basisCategories of personal data used for this purpose
Provision of ServicePerformance of ContractRegistration data, student data
Provision of educational and career opportunities for graduating studentsConsentGraduating students' data related to education and professional qualification
Service improvementLegitimate InterestRegistration data, student data, other data, cookies
Inform active and potential students about our courses and educational opportunitiesConsent, legitimate interestStudent data, registration data (with the data subject's consent), other data, tutor data
For marketing, promotion, and advertising purposes, including targeted advertising based on your personal data that we collectConsent, legitimate interestOther data, student data, registration data (with the data subject's consent), cookies
Ensuring the security and integrity of our network and detecting, investigating, and preventing activities that may violate our policies and terms, cause security problems, or be fraudulent or illegal.Legitimate InterestOther data, student data, registration data, tutor data
Compliance with legal obligations and requests or regulatoryCompliance with obligation legal or regulatoryRegistration data, student data, other data, cookies, tutor data
Establish, exercise, or defend legal rightsLegitimate InterestRegistration data, student data, other data, cookies, tutor data
Perform planning, prepare reports, and make business forecastsLegitimate InterestRegistration data, student data, other data, cookies, tutor data
Conduct research, surveys, and contestsPerformance of Contract, legitimate interest, consentRegistration data, student and graduating student data, other data, cookies, tutor data
Record video conferences and communications in chats, monitor and improve service quality, and defend legal claims.Legitimate Interest, consentCorrespondence and calls between users and Grow10x's support team

When applicable data protection laws require that we process certain personal data only with your explicit consent (or another lawful basis), we will obtain that consent or rely on the appropriate legal ground. In those circumstances, the table above applies only insofar as its purposes, legal bases, and data categories comply with the relevant legal requirements.

Accordingly, the lawful bases we rely on to process your personal data may differ depending on the data protection laws in your country of residence.

4. How we share your personal data

Disclosure of Your Personal Data

We may disclose your personal data to the following recipients, to the extent required or permitted by applicable law and in line with your legitimate requests:

  • Tutors and Academic Staff: To the extent necessary for them to deliver and support the educational Services.
  • Affiliated Companies: Other entities within the Grow10x corporate group, solely to enable seamless Service provision.
  • Educational & Career Partners: Organizations that help identify and create learning or job opportunities for our students.
  • Service Providers: Third‑party vendors who support our operations, including:
    • IT and technical support
    • Legal advisors and accountants
    • Payment providers
    • Cloud hosting and data storage providers
    • Sales and marketing agencies
    • Analytics
  • Other Service Partners: Any additional vendors or consultants engaged to help us deliver the Service or fulfill the purposes described in Section 3 of this Privacy Policy.
  • Public Authorities: When strictly necessary to comply with legal or regulatory obligations, or to respond to formal inquiries.
  • Financial Institutions: Lenders or other financial service providers, where needed to facilitate payments, loans, or related services.
  • Other Third Parties: As required to comply with applicable laws or court orders.
  • Business Transferees: In connection with a sale, merger, corporate restructuring, or transfer of all or part of our business, assets, or rights and obligations.

All third parties listed above may only process your personal data for the specific purposes of performing their contractual functions and are prohibited from using it for any other purpose.

Payment processing

When you purchase our courses or other products, you may be redirected to external websites operated by our trusted payment service providers. Once your payment is completed, we only receive confirmation of the transaction status.

We do not collect, access, or store any of your payment details (e.g., card numbers, bank account information).

We have no control over and cannot view any information you enter on the payment provider’s site.

All payment processing is handled directly by the third‑party provider under its own privacy policy.

Please note that any data you submit during checkout is subject to the provider’s terms and privacy practices, over which Grow10x has no control.

5. External Links & Third‑Party Services

Our Privacy Policy explains how we collect, use, protect, and disclose your personal data within the Grow10x Service. However, the Service may include links to external websites and platforms not operated by Grow10x, for example, Zoom and other video‑conferencing or webinar tools that enable you to attend classes online.

  • Separate Registration: These third‑party providers may require you to register independently, and they operate under their own terms and privacy policies.
  • No Control or Responsibility: Grow10x does not control, endorse, or assume any liability for the content, privacy practices, or security measures of these external sites and services.
  • Different Privacy Policies: This Privacy Policy does not cover how those third parties collect, use, or share your personal data, even if they are branded as Grow10x partners.

WE STRONGLY RECOMMEND THAT YOU REVIEW THE PRIVACY POLICY OF ANY THIRD-PARTY SITE OR SERVICE YOU ACCESS THROUGH OUR SERVICE.

6. How your personal data is stored, transferred, and protected

6.1. Transfers to third countries

Grow10x is a global company. We may transfer, store, and process your personal data outside your country of residence, including in the United States, the European Economic Area (“EEA”), Brazil, and other jurisdictions where our subprocessors and service providers operate. These transfers enable us to deliver, host, and support the Service worldwide.

Key details for each transferForm of Transfer

United States: cloud hosting, data backup, customer support, analytics, marketing, R&D

Brazil: analytics, email delivery, localized marketing.

Other jurisdictions where our processors maintain data centers, strictly to perform contracted functions.

Electronic transfers over secure, encrypted channels (e.g. HTTPS).

Data may be stored on servers operated by our cloud and service providers.

To ensure your data receives adequate protection, we rely on one or more of the following, as permitted by applicable law:

  • We may transfer your personal information to countries whose privacy laws have been recognized by the country of origin of the data as offering similar protections for the data (“adequacy”).
  • We may enter into written agreements, such as standard contractual clauses and other data transfer agreements, with recipients, requiring them to provide the same level of protection for personal information.
  • We may request your consent for transfers of your personal information for specific purposes.
  • We may rely on other transfer mechanisms approved by the authorities of the country of origin of the personal information.

For full transparency on our international data transfer practices, including complete lists of recipients and detailed data processing agreement(s), data subjects may request more information by contacting us at support@grow10x.io (see Section 1) or the designated Data Protection Officer, as indicated in the jurisdiction-specific sections.

6.2. Storage of personal data

We retain your personal data only for as long as necessary to fulfill the purposes described in Section 3 of this Privacy Policy, while your account is active and for up to seven (7) years thereafter (or longer if required to meet legal obligations). Once that period expires, we will securely delete or irreversibly anonymize your personal data.

6.3. Data Security

We implement appropriate physical, technical, and organizational safeguards proportional to the sensitivity of the personal data we collect to help protect against accidental loss, unauthorized access, or disclosure. These measures include, but are not limited to:

  • Physical controls: Secure facilities and access badges.
  • Technical controls: Encryption in transit and at rest, firewalls, intrusion detection, and regular security testing.
  • Organizational controls: Access restricted on a “need‑to‑know” basis, staff training, and formal security policies.

Please note that, while we strive to protect your data, no security measures are completely impenetrable. We cannot guarantee that information you transmit to us over the Internet will never be intercepted.

7. Basic Rights of Data Subjects

Below, you’ll find a table outlining your rights and their descriptions as they apply to your jurisdiction.

RightDescription
Access and ConfirmationYou may ask Grow10x to confirm whether or not we process your personal data. If so, you may access this personal data and request that we explain certain details of the processing.
Rectification (correction of incomplete, inaccurate, or outdated data)You may ask us to correct your personal data if it is inaccurate. If this is in conformity with the purposes of processing, you may request the rectification of incomplete or inaccurate personal data.
Deletion or anonymizationYou may ask us to eliminate or anonymize personal data related to you as per applicable law. For example, this applies when (1) personal data is no longer necessary for the purposes of processing; (2) you revoke your consent for the processing, and there is no other legal basis for the processing; 3) if personal data is unnecessary or has been processed in non-compliance with applicable law.
Restriction of processingYou may request the restriction (blocking) of certain personal data to limit the future process data as per applicable law. This applies if (1) you contest the accuracy of the personal data; (2) you ask to restrict the use of personal data when the process is non-compliant with applicable law ; (3) you need to limit the processing of personal data to protect your rights, while Grow10x no longer needs the personal data; (4) you object to the data processing based on the legitimate interests pursued by us or a third party.
Objection to processing (if provided to the data subject according to applicable laws)You may object at any time, for reasons related to your particular situation, to the processing of personal data related to you if it is based on one of the hypotheses of consent exemption, in case of non-compliance with applicable law. We will cease to process your personal data, unless we can demonstrate a legal basis for the data processing that overrides your interests, rights, and freedoms, or for the compliance with a legal or regulatory obligation or regular exercise of rights.
Portability (if provided to the data subject according to applicable laws)When the data processing is based on your consent or on a contract you signed with us, you may receive the personal data you provided to Grow10x in a structured, commonly used, and machine-readable format and freely transmit this data to another controller. Whenever technically possible, the data subject may also request that Grow10x transmit the personal data directly to another controller.
Information about public and private entities with which personal data has been sharedIf Grow10x carries out the shared use of your personal data with other public or private entities, you may request information about the entities.
Information about the possibility of not providing consent and about the consequences of refusalWhen the processing of personal data is based on your consent, you may be informed about the consequences of refusal, should you not provide your consent.
Review of automated decisions (if allowed to the data subject according to applicable laws)When the processing of personal data involves an automated decision, you may request a review of this decision, should it affect your interests.

To exercise your rights (subject to any legal limitations), please contact us using the details provided in Section 1 of this Privacy Policy or the designated Data Protection Officer, as indicated in the jurisdiction-specific sections.

8. Withdrawal of Consent

If our processing relies on your consent, you may withdraw that consent at any time without affecting the lawfulness of any processing carried out before your withdrawal.

To opt out of electronic communications, you can:

  • Reply “STOP” to any SMS message;
  • Click the “unsubscribe” link in our emails; or
  • Contact us directly using the details in Section 1 of this Privacy Policy.

9. Right to File a Complaint

Where granted by applicable law, you may lodge a complaint with the data protection authority in your country of residence.

10. Necessity of Providing Personal Data

We only collect the personal data strictly necessary to deliver the Service and to fulfill the purposes described in Section 3 of this Privacy Policy.

There is no legal or contractual requirement for you to share your personal data with Grow10x providing such information is entirely voluntary, and you may choose not to disclose any personal data to us.

11. Children's Privacy

No Collection from Minors: We do not knowingly collect personal data from anyone under eighteen (18) years of age.

Under‑18 Users: If you are under 18, please do not register for our Service or submit any personal information.

Parental Rights: If you are a parent or legal guardian and believe that your child under 18 has provided us with personal data in violation of this Policy, please contact us using the details in Section 1 of this Privacy Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy at any time, at our sole discretion. If we make significant changes, we will notify you by appropriate means (for example, via email or a notice on our website). If you do not receive a direct notification, you can always review the latest version here.

Each time we amend this Policy, the “Last updated” date at the top will reflect the change. We recommend that you check this page periodically to stay informed of any updates. All changes take effect immediately upon posting.

13. Difficulties in accessing this Privacy Policy

If you have difficulty accessing this Privacy Policy online, please contact us using the details in Section 1. We will provide you, at no cost, with a copy of this Policy in an alternative, easy‑to‑read format, upon request.

Please note that we will not collect or process any additional sensitive personal data, such as health information in connection with your request for an alternative format.

14. STATE/COUNTRY-SPECIFIC PRIVACY PROVISIONS

A. Residents in Brazil

You may contact Grow10x, the data controller, to exercise any of your rights provided in this Privacy Policy.

According to the Brazilian General Data Protection Law and applicable regulations, Grow10x has appointed Grow10x as Data Protection Officer (DPO). You may contact the DPO through the e-mail address support@grow10x.io.

The email address support@grow10x.io is also designated for official communications with Brazilian National Data Protection Authority (“Autoridade Nacional de Proteção de Dados” or “ANPD”).

B. Privacy information for California residents

This section of the Privacy Policy is valid only for California residents. Where applicable, this section shall prevail over all other parts of the Privacy Policy in case of discrepancies.

Personal information collected during the last 12 months.

The personal information we collect directly from you:

Categories of data collectedYour data collected by us and why it was collected
IdentifiersDepending on the data subject category defined in Section 2, we may collect the following data:
  • full name;
  • email;
  • phone number;
  • address;
  • age (when the user is under 18 years old);
  • postal code;
  • information about your work authorization.
Characteristics of protected classifications under California or federal law
  • gender;
  • presence of children
Commercial informationrecord of Grow10x services purchased or considered for purchase
Geolocation dataNo data
Financial informationNone. Please note that we use third-party payment processors to facilitate your payments and do not store your payment card data.
Biometric dataNo data.
Audio, electronic, visual, thermal, olfactory, or similar information.No data.
Internet/network activityAs described in Section 11: Cookies.
Professional or employment-related informationDepending on the data subject category defined in Section 2, we may collect the following data:
  • area of interest or profession;
  • professional experience;
  • professional status;
  • work authorization.
Educational informationThe highest degree or level of education and your field of study;
Device informationNo data

We do not sell your personal information to third parties.

Categories of personal information disclosed during the last 12 months:

Categories of data disclosedTypes of entities to which your data was disclosedReason for data disclosure
Identifiers, Characteristics of protected classifications under California or federal law, Commercial information, Internet/network activity, Professional information, employment-related and educationalCategories of recipients: Please see Section 4.Service provision, Improve services, inform active and potential students about courses and educational opportunities, to ensure the security and integrity of our network and detect, investigate, and prevent activities that may violate our policies and terms, cause security problems, or be fraudulent or illegal. for marketing, promotion, and advertising purposes, to comply with legal obligations and requests, establish, exercise, or defend legal rights, perform planning, prepare reports, and make business forecasts; conduct research, surveys, and contests.

Information that we sell

We do not sell your personal information to third parties.

Your California privacy rights

We have policies and procedures that facilitate the exercise of privacy rights available to California residents under applicable law. If you are a California resident, you may have the right to the following:

Submitting a verifiable request in accordance with the LPCC

As mentioned above, California residents have certain rights to access, delete their personal information, or otherwise exercise their rights under the California Consumer Privacy Act of 2018 ("California Consumer Privacy Act of 2018"). Grow10x will respond to a "verifiable request" from an individual to exercise their rights under the LPCC – that is, when Grow10x receives a request purportedly sent by a particular individual and can verify the individual's identity. The need to verify an individual's identity is crucial for us to protect your information and ensure that it is not shared with someone pretending to be you or someone not authorized to act on your behalf.

Submitting a request for removal of minors' information

To request the removal of information about minors from this website, their parents or guardians may submit a request with the subject "Removal of minors' information." These requests must be submitted by a child's parent or legal guardian; minors cannot send us information via email.

Our policy on "Do Not Track" signals under California online protection law

We do not support Do Not Track. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable "Do Not Track" by visiting your web browser's "Preferences" or "Settings" page.

Third parties may collect data related to you. We cannot control third-party responses to do-not-track signals or other such mechanisms. The use of data related to you by third parties and their responsiveness to do-not-track signals are governed by their respective privacy policies.

How to contact us/Submit a LPCC inquiry.

If you are a California resident and have any questions about this Privacy Policy, our practices, or your personal information, please contact us using the contact information at the top of this Policy.

C. Privacy Information for Residents of other States

(Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia):

Unless otherwise stated by the law of your state of residence, the provisions in Chapter B “Privacy Information for California Residents” will apply to the processing of your data. If you have questions related to your rights or any other aspects of this Privacy Policy, please contact us using the methods outlined in Section 1.

Your Rights under various United Sates state data privacy laws such as the Colorado Privacy Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Indiana Consumer Data Protection Act, Iowa Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire SB 255, New Jersey SB 332, Oregon Consumer Privacy Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act.

For residents from the states of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia this section allows you to exercise your rights under the applicable state law.

  • Right to Confirm: The right to confirm whether your personal data is being processed.
  • Right to Access / Disclosure: The right to have access to your personal data upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing of your data.
  • Right to Data Portability: the right to obtain, move, copy, or transfer data as defined by applicable law.
  • Right to Correction/Rectification: The right to correct your personal data if you find it is inaccurate, incomplete or obsolete.
  • Right to Deletion: The right to obtain the deletion of your personal data in the situations set forth by applicable data protection law.
  • Right to Opt-Out: The right to opt out of the processing of your personal data for targeted advertising, as defined by applicable law as well as the right to opt out of the processing of sensitive data as defined by applicable law. Certain applicable laws also permit the right to opt out of the sale of personal data and profiling.
  • Right to Appeal: You may also have the right to appeal the denial of any of these rights by submitting a form that will be provided to you if we deny a data request.

Submitting a Verifiable Request under the United States’ State Laws.