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Privacy Policy

Updated on 25, July 2025

GrowthTrigger Pte. Ltd.

Last Updated: January 2025

GrowthTrigger Pte. Ltd. ("GrowthTrigger," "we," "our," or "us") respects your privacy and is committed to protecting it through this Privacy Policy. This Privacy Policy explains what information we collect when you visit our website at growthtrigger.com (the "Website"), how we use this information, and the security measures we employ to protect your data.

1. Who We Are

GrowthTrigger Pte. Ltd. is a retention marketing agency specializing in email and SMS marketing services for telehealth and DTC health brands. We provide HIPAA-compliant marketing automation, patient lifecycle optimization, and full-stack retention management services.

Contact Information:
GrowthTrigger Pte. Ltd.
Email: team@growthtrigger.xyz
Website: https://growthtrigger.com

2. Information We Collect

2.1 Information You Provide to Us

We collect Personal Information when you:

Fill out contact forms, inquiry forms, or audit request forms
Sign up for our newsletter or marketing communications
Register for webinars, events, or download resources
Engage our services and become a client
Correspond with us via email, phone, or other channels

Personal Information may include:

Name and job title
Company name and industry
Email address
Phone number
Business address
Website URL
Information about your telehealth or health brand
Marketing preferences and interests

2.2 Information Collected Automatically

When you visit our Website, we automatically collect certain information through cookies, web beacons, and similar technologies:

Technical Information: IP address, browser type and version, device type, operating system
Usage Information: Pages visited, time spent on pages, links clicked, referring website, date and time of visits
Analytics Data: User journey through the Website, interaction with content and features

2.3 Information from Third Parties

We may collect information about you from:

Publicly available sources (LinkedIn, company websites, professional directories)
Business contact databases and lead generation platforms
Marketing partners and referral sources
Analytics and advertising platforms

2.4 Client Data

If you engage our services, we will collect and process data related to your business operations, including:

Customer/patient data you provide for retention marketing services
Email and SMS campaign performance data
Marketing automation platform credentials (Klaviyo, Customer.io, etc.)
Business performance metrics and analytics

Important: We handle patient health information in accordance with HIPAA compliance requirements and execute Business Associate Agreements (BAAs) where applicable.

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Delivery

Provide retention marketing services as contracted
Configure, manage, and optimize email/SMS campaigns
Monitor campaign performance and provide reporting
Troubleshoot technical issues and provide support

3.2 Communication

Respond to inquiries and service requests
Send service-related communications and updates
Provide customer support and account management
Send contractual notices and invoices

3.3 Marketing

Send newsletters, industry insights, and educational content
Promote our services, case studies, and resources
Invite you to webinars, events, and training sessions
Share relevant content based on your interests

3.4 Business Operations

Improve our Website, services, and user experience
Analyze trends and gather market intelligence
Develop new services and features
Conduct internal research and analytics

3.5 Legal and Compliance

Comply with legal obligations and regulatory requirements
Enforce our Terms and Conditions
Protect our rights, property, and safety
Prevent fraud and abuse

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), we process your Personal Information under the following legal bases:

Consent: You have given clear consent for us to process your Personal Information for specific purposes (e.g., marketing communications)
Contract Performance: Processing is necessary to perform a contract with you or take steps at your request before entering into a contract
Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., improving services, fraud prevention) and does not override your fundamental rights
Legal Obligation: Processing is necessary to comply with legal or regulatory requirements

5. Cookies and Tracking Technologies

5.1 What Are Cookies?

Cookies are small text files stored on your device that help us recognize your browser and remember information about your visit.

5.2 Types of Cookies We Use

Cookie Type

Purpose

Duration

Essential Cookies

Enable basic Website functionality and security features

Session

Performance Cookies

Collect anonymous data about how visitors use our Website

Persistent

Functionality Cookies

Remember your preferences and settings

Persistent

Marketing Cookies

Track visitors across websites to display relevant advertising

Persistent

Analytics Cookies

Help us understand Website traffic and user behavior (Google Analytics, etc.)

Persistent

5.3 Managing Cookies

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our Website.

Third-Party Cookies: We use services like Google Analytics, LinkedIn Insight Tag, and Facebook Pixel. These third parties have their own privacy policies governing cookie use.

6. How We Share Your Information

We do not sell, rent, or trade your Personal Information. We may share your information with:

6.1 Service Providers

Third-party vendors who assist us in operating our business:

Email service providers (for newsletters and communications)
CRM and marketing automation platforms
Analytics and data intelligence providers
Payment processors and accounting services
Web hosting and infrastructure providers

6.2 Business Partners

Co-marketing partners (with your consent)
Referral partners and affiliates
Event sponsors and co-hosts

6.3 Legal Requirements

We may disclose your information when required by law or to:

Comply with legal processes (subpoenas, court orders)
Enforce our agreements and policies
Protect our rights, property, and safety
Prevent fraud or security threats

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity.

7. HIPAA Compliance and Protected Health Information (PHI)

7.1 Business Associate Relationship

When providing services to telehealth clients that involve access to Protected Health Information (PHI), GrowthTrigger acts as a Business Associate under HIPAA regulations. The specific terms of our HIPAA compliance obligations are detailed in the Business Associate Agreement (BAA) executed separately with each covered entity client.

We implement administrative, physical, and technical safeguards to protect PHI as required by HIPAA and our Business Associate Agreements.

7.2 PHI Use Restrictions

We use and disclose PHI only as:

Necessary to provide contracted retention marketing services
Required by law or permitted under HIPAA regulations
Authorized by the covered entity through the BAA

7.3 Patient Rights

If you are a patient of one of our telehealth clients and have questions about how your health information is used for marketing purposes, please contact the telehealth provider directly.

8. Data Security

We implement industry-standard security measures to protect your information:

8.1 Technical Safeguards

SSL/TLS encryption for data transmission
Encryption of sensitive data at rest
Secure authentication and access controls
Regular security audits and vulnerability assessments
Firewalls and intrusion detection systems

8.2 Administrative Safeguards

Access controls limiting data access to authorized personnel only
Employee training on data protection and privacy
Confidentiality agreements with staff and contractors
Incident response and breach notification procedures

8.3 Physical Safeguards

Secure data centers with restricted access
Environmental controls and monitoring
Secure disposal of physical media containing Personal Information

No system is 100% secure: While we strive to protect your information, we cannot guarantee absolute security. You acknowledge that you provide information at your own risk.

9. Data Retention

We retain your Personal Information for as long as:

You remain a client or service user
Necessary to fulfill the purposes outlined in this Privacy Policy
Required by legal, regulatory, or contractual obligations
Needed for dispute resolution and enforcement of agreements

Retention Periods:

Client Data: Duration of engagement plus 7 years for accounting/legal compliance
Marketing Data: Until you unsubscribe or request deletion
Website Analytics: Aggregated data retained indefinitely; individual data 26 months (Google Analytics default)

10. Your Rights and Choices

10.1 Marketing Communications

You may opt out of marketing communications at any time by:

Clicking the "unsubscribe" link in any marketing email
Emailing us at team@growthtrigger.xyz
Updating your communication preferences if available

Note: Opting out of marketing does not affect service-related communications if you are a client.

10.2 GDPR Rights (EEA, UK, Switzerland Residents)

If you are located in the EEA, UK, or Switzerland, you have the following rights:

Right to Access: Request copies of your Personal Information
Right to Rectification: Request correction of inaccurate or incomplete data
Right to Erasure ("Right to be Forgotten"): Request deletion of your Personal Information
Right to Restriction: Request limited processing of your data
Right to Data Portability: Receive your data in a structured, machine-readable format
Right to Object: Object to processing based on legitimate interests or for direct marketing
Right to Withdraw Consent: Withdraw consent at any time (does not affect lawfulness of prior processing)
Right to Lodge a Complaint: File a complaint with your local data protection authority

To exercise these rights, contact us at team@growthtrigger.xyz. We will respond within 30 days.

10.3 CCPA Rights (California Residents)

If you are a California resident, you have the right to:

Know: Request disclosure of categories and specific pieces of Personal Information collected
Delete: Request deletion of your Personal Information
Opt-Out: Opt out of the "sale" of your Personal Information (Note: We do not sell Personal Information)
Non-Discrimination: Not receive discriminatory treatment for exercising your rights

To exercise these rights, contact us at team@growthtrigger.xyz.

10.4 Cookies and Tracking

You can manage cookies through your browser settings or use opt-out tools:

Google Analytics: https://tools.google.com/dlpage/gaoptout
Network Advertising Initiative: https://optout.networkadvertising.org/
Digital Advertising Alliance: https://optout.aboutads.info/

11. International Data Transfers

GrowthTrigger is based in Singapore. If you access our Website or use our services from outside Singapore, your information may be transferred to, stored, and processed in Singapore or other countries where we or our service providers operate.

For EEA/UK Users: We ensure adequate safeguards for international transfers through:

Standard Contractual Clauses (SCCs) approved by the European Commission
Adequacy decisions by the European Commission
Other approved transfer mechanisms under GDPR

12. Third-Party Links

Our Website may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices or content of these third parties. We encourage you to review their privacy policies before providing any information.

13. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If we learn that we have collected information from a child under 18, we will delete it promptly. Please contact us at team@growthtrigger.xyz if you believe we have collected information from a child.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of material changes by: