PRIVACY POLICY

Effective September 5, 2017
PRIVACY POLICY

1. OVERVIEW

This privacy policy (this “Privacy Policy”) describes how Clutch Brands, Inc. (“we,” “us” or “GrowthBoks”) maintains, uses and shares information that we may collect when you use our websites at www.growthboks.com, www.zerotogrowthengine.com (the “Sites”) and any products or services made available from time to time by means of any of the Sites (the “Products”). We refer to the Sites and the Products collectively in this Privacy Policy as the “Services.” By using any of the Services, you acknowledge that you have read, understood, and agree to the provisions of this Privacy Policy.
We may change this privacy policy from time to time. Any such changes will be posted here. If we make a material change in the way we use your personal information, we will prominently note the change on the Services and/or email you regarding the change.

2. HOW WE COLLECT AND USE INFORMATION

Some of the information we collect when you use the Services, such as your name, postal address, email address, credit card information or telephone number, may allow you to be identified (“Personal Information”). In all of the following circumstances, we will use Personal Information for the purpose described below, as well as to supplement our database of marketing contacts, which we will use to provide and promote products and services from us or our marketing affiliates.

Registration: When you register on the Services, such as to subscribe to a newsletter, request information or access a Product, you will be asked to provide certain Personal Information, which we will use to fulfill your request.
Surveys: We may ask you to complete surveys or opinion polls from time to time. We only use the information that we collect from surveys in an aggregate manner, not in individually identifiable form.

Blogs and Forums: We may provide an opportunity for you to post information to blogs, forums or other public areas on the Services. By doing so, you consent to the posting of any Personal Information that you provide. You should be aware that such Personal Information can be read, collected, or used by other visitors to these public areas. We have no control over how these visitors use your Personal Information.

Inquiries. If you send us a comment or question or make an inquiry to customer support, we will retain the information that you provide to us for the purpose of responding to you, as well as for improving the Services and our customers’ use of our services.

Linking from Emails. If you link to any of our Sites from an email message from us, we will be able to identify your email address and associate that email address with the manner in which you use the Sites (e.g., which pages you visit or whether you make a purchase).

Visitors: If you are just visiting the Sites and not registering, requesting information, contacting us, or posting to a public area of the Services, and you did not access the Sites from a link contained in one of our email communications, we will not ordinarily collect any Personal Information about you except through web logs, as described below. In that case, we obtain the information that you provided and will use it to respond to your inquiry or fulfill your request if we can. We do not share any of this information with anyone else, except to respond to your request, if you consent, or as otherwise described in this privacy policy.

Web Logs: We maintain web logs that automatically record basic information about everyone who visits the Services. We use web log information to help us design our website, to identify popular features, to improve our services, and for other managerial and analytic purposes. We may also use web logs to help identify any person who may be misusing the Services. These logs contain:

• The Internet domain from which you access the Services.
• Your IP address.
• The type of browser and operating system that you use.
• The date and time you visited the Services.
• The pages that you visited on the Services.
• The address of the website you linked from to get to the Services.

Cookies: We use cookies, web beacons and similar technology to help you navigate the Services, to allow us to learn how you use the Services, and to improve the Services. Cookies are text files we place in your computer’s browser to store your preferences. Cookies, by themselves, do not reveal any Personal Information unless you choose to provide this information to us by, for example, registering at our Site. However, once you choose to provide Personal Information to the Services, this information may be linked to the data stored in the cookie. If you decide not to permit cookies on your computer, this may affect your ability to use the Services.

Communicating with You. We may use information that we collect from you for the purpose of communicating with you and responding to your inquiries. Those communications could, for example, take the form of service updates, promotions for products or services that we or one of our marketing partners provide, or e-newsletters.

Service Providers: We at times contract with third party service providers to perform functions for us. These service providers may be given access to the information we collect for the purpose of performing those functions, but they will be contractually bound to maintain the confidentiality of the information and not to use it for any other purpose.

Social Media. The Sites may include social media features, such as Facebook “Like” button and a “Share” button. These features may collect your IP address and which page you are visiting on the Site; and they may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company that provides the feature.
Business Transfers: If we were to transfer all or substantially all of our assets to another company, one of the assets we would likely include in the transfer is our database of Personal Information.

Disclosures for Legal Reasons: We will disclose Personal Information when we are required to do so by law, regulation or securities exchange requirement, for example, in response to a court order or subpoena. We also may disclose such information in response to a law enforcement agency’s request or when we believe such disclosure is appropriate to protect our legal rights or to safeguard anyone’s property or safety.

3. COLLECTION OF INFORMATION BY THIRD PARTIES

We may use a third-party advertising company to serve ads when you visit our Site. If we do so, this company may use information (not including your name, address, email address or telephone number) about your visit to the Services in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements to the Services, the advertiser might place or recognize a unique “cookie” on your browser.

We may offer you the opportunity to contact other companies, such as advertisers, marketing affiliates and content providers, to obtain information or to buy products or services. You decide when and whether to give your Personal Information to these companies. If you provide information, its use and security is governed by the policies and practices of those companies and not by this privacy policy.
We make no representations or warranties about any of these other companies or their privacy or security policies. Once you click through to an unaffiliated website, this privacy policy no longer applies. We strongly urge you to read the applicable policies of these other companies and their websites.

4. YOUR PRIVACY CHOICES

If you would like us to stop sending you email or other communications or would like to access your Personal Information to correct or delete it, you may send us a request at our email or postal addresses indicated below. We will endeavor to satisfy such requests within a reasonable time.

5. DO NOT TRACK.

There will be no difference in how we collect or use data if you set your web browser to send a “Do not track” or similar request when you visit this Site.

6.LINKS.

Our Site includes links to other websites whose privacy practices differ from ours. If you submit personal information to any of those websites, your information will be subject to their practices and policies.

7.SECURITY

We maintain all Personal Information with physical, electronic, and managerial safeguards to help ensure the security and confidentiality of the data against reasonably foreseeable risks. Security is designed to prevent unauthorized use, access, disclosure, destruction, and changes of data.

8.CHILDREN

This Site is intended for use by adults. We do not target, or knowingly collect any Personal Information from, children under the age of 13.

9.ACCOUNTABILITY

We are committed to adhering to our privacy policy and applicable laws and to making your online experience secure and valuable. If you have a question, request, complaint, dispute or concern related to this privacy policy, you may send a message by email to support@growthboks.com or in writing to Clutch Brands, Inc., Attn: Customer Support, 1100 University Ave #321, Rochester, NY 14607. We will work with you to obtain a prompt resolution of any issues you may have.