Privacy Policy
About This Policy
The Growth Layer LLC (“The Growth Layer,” “we,” “us,” “our”) is a growth marketing and AI transformation agency. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit thegrowthlayer.com, contact us, receive our services, or subscribe to our communications.
We operate in two distinct capacities. When you visit our website, fill out a form, or subscribe to our newsletter, we determine how your information is used — we are the data controller. When we process data on behalf of clients to deliver agreed services (ad targeting, lifecycle campaigns, analytics), our clients determine the purpose — we act as a data processor or service provider. This policy primarily covers our role as data controller. If your rights request relates to data we process on behalf of a client, please contact that client directly.
1. Information We Collect
A. Information you provide directly
When you fill out a contact form, request a growth audit, book a discovery call, subscribe to our newsletter, or apply for a position, you may provide: name, email address, company name, job title, phone number, website URL, revenue stage, business description, and any other details you choose to include.
B. Information collected automatically
When you visit our site, we and our service providers automatically collect: IP address, browser type and version, operating system, device type, pages visited, time on page, referring URL, and general geographic location (city/region, derived from IP). This data is collected via cookies and tracking technologies described in Section 3.
C. Client and campaign data (processor role)
Clients may grant us access to their customer data, ad platform accounts, CRM systems, and analytics properties. This includes consumer profiles, transaction records, behavioral data, and audience lists. We process this data solely to deliver contracted services and do not use it for our own purposes. If you are a consumer whose data is processed through a client campaign, contact that client to exercise your privacy rights.
2. How We Use Your Information
When acting as a data controller, we use your personal information to:
- Respond to inquiries, growth audit requests, and discovery call bookings
- Contact you via email, phone, or text message about our services, including follow-up on forms you submit
- Send marketing communications including our newsletter, blog, and promotional content — you can opt out at any time
- Run targeted and retargeted advertising on third-party platforms (Meta, Google, LinkedIn, and others) to promote our services, including through email-based custom audiences
- Deliver, manage, and improve our services
- Analyze website and marketing performance
- Comply with legal obligations and enforce our agreements
- Evaluate employment applications
- Detect and prevent fraud, abuse, and unauthorized access
Legal bases for processing (where applicable): performance of contract, legitimate business interests, consent (for marketing communications, SMS, and non-essential cookies), and legal obligation.
3. Marketing Communications and Outreach
By submitting your contact information through any form on our site — including contact forms, the growth audit request, newsletter sign-up, or discovery call booking — you consent to being contacted by The Growth Layer regarding our services, content, and growth resources.
We send marketing emails including newsletters, service announcements, growth resources, and promotional content. We also send transactional emails related to requests you initiate (booking confirmations, audit follow-up, form acknowledgment). To opt out of marketing emails, use the unsubscribe link in any email or contact privacy@thegrowthlayer.com. Transactional emails will continue as they are necessary to fulfill your request.
If you provide a phone number, we may contact you via text message to follow up on inquiries, share service information, or send appointment reminders. Message and data rates may apply. To opt out of SMS communications, reply STOP to any text message from us or contact privacy@thegrowthlayer.com. Message frequency varies.
We may call you to follow up on submitted forms, discuss your growth needs, or schedule a discovery session. To opt out of phone outreach, contact privacy@thegrowthlayer.com or tell us directly during any call.
We comply with applicable marketing laws including CAN-SPAM, TCPA, and state-level requirements. Consent to marketing communications is not a condition of receiving our services.
4. Cookies, Tracking, and Remarketing
We use cookies, pixels, tracking scripts, and similar technologies on our website. These technologies help us understand site behavior, improve our marketing, and reach users with relevant advertising across the web.
Required for the site to function. Cannot be disabled. Do not store personal information and are never used for advertising.
We use Google Analytics and HubSpot to understand how visitors use our site. HubSpot’s tracking pixel may load automatically if you have previously interacted with us. This data is used to improve our content and marketing.
Cookies that remember preferences and enable features such as the Cal.com scheduling widget and form pre-fill.
We run retargeting and remarketing campaigns on Meta (Facebook/Instagram), Google, LinkedIn, and similar platforms. These platforms set cookies when you visit our site and may serve our ads to you elsewhere based on your visit. We also use email-based custom audiences (hashed email matching) to reach known contacts on these platforms — for example, Facebook Custom Audiences, Google Customer Match, and LinkedIn Matched Audiences. If you have submitted your email to us, it may be uploaded in hashed form to these platforms for ad matching. You can opt out of interest-based advertising through the Digital Advertising Alliance (optout.aboutads.info), the Network Advertising Initiative (optout.networkadvertising.org), or through each platform’s ad settings.
Manage cookies through your browser settings. Disabling certain cookies may affect site functionality. We honor Global Privacy Control (GPC) signals where required by law.
5. AI Tools and Automated Processing
We use AI-powered tools — including large language models, AI agents, and automation platforms — in our internal operations and as part of client service delivery. These tools may process personal information as part of workflow automation, content generation, data analysis, creative production, and reporting.
All AI-generated outputs are reviewed by our team before use in client-facing work. We maintain human oversight over AI processing at all stages.
We will not use client data to train third-party AI models. When we use AI platforms to process client data, we do so under data processing agreements that expressly prohibit model training on that data.
6. How We Share Your Information
We share personal information only where necessary and legally permitted. We do not sell personal information. We do not share personal information for cross-context behavioral advertising as defined under California law, except through advertising platforms used to deliver our own promotional campaigns as described in Section 4.
Vendors who help us operate our business: HubSpot (CRM, email marketing, contact tracking), Google Analytics and Google Ads (analytics and advertising), Meta Ads (advertising), LinkedIn Ads (advertising), Cal.com (scheduling), Vercel (hosting and APIs), and similar tools. All vendors process data only on our behalf under data processing agreements.
When we upload email addresses to advertising platforms (Meta, Google, LinkedIn) to create custom audiences for our own campaigns, those platforms receive hashed versions of your email. This is for our advertising only and governed by each platform’s data use terms. Platform use of matched data is subject to their own privacy policies.
If you register for a co-hosted event or co-produced content, we will disclose co-sponsors at the point of registration and may share your information with them. You will have the ability to decline at registration.
Lawyers, accountants, auditors, and insurers where necessary for legitimate business operations, under appropriate confidentiality obligations.
We may disclose information in response to a valid subpoena, court order, or government request, or where we believe disclosure is necessary to protect our rights, prevent fraud, or ensure the safety of any person.
If The Growth Layer is acquired, merged, or substantially all assets are transferred, personal information may be included in the assets transferred. We will notify you via email or prominent site notice if this occurs and a change in data use is involved.
7. Data Transfers
Our servers and primary vendors are located in the United States. If you are outside the US, your information will be transferred to and processed in the US, where data protection laws may differ. By submitting information or using our site, you acknowledge this. Where required by applicable law, we put appropriate safeguards in place for international transfers, including standard contractual clauses.
8. How Long We Keep Your Data
We retain personal information only as long as necessary for the purposes described in this policy, to comply with legal obligations, resolve disputes, and enforce our agreements. General retention guidelines:
- Website inquiries and growth audit submissions: up to 3 years from last contact
- Active newsletter and marketing list subscribers: for the duration of your subscription
- Marketing suppression list (opted-out contacts): retained indefinitely to prevent re-contacting you
- Client records: duration of the engagement plus up to 5 years for legal and accounting purposes
- Site analytics data: per vendor retention settings, typically 13–26 months
We may retain deidentified or aggregated data beyond these periods.
9. Security
We implement industry-standard technical and organizational measures to protect your personal information, including encrypted data transmission (HTTPS), access controls, and vetted third-party processors. No security system is perfect, and we cannot guarantee absolute security. If you believe your information has been compromised, contact privacy@thegrowthlayer.com immediately.
10. Children
Our website and services are not directed to individuals under 16. We do not knowingly collect personal information from children. If we learn we have collected information from someone under 16, we will delete it promptly. Contact privacy@thegrowthlayer.com if you believe we have collected such information.
11. Your Rights and Choices
Depending on your location, you may have the following rights regarding your personal information:
- Access: Request a copy of the personal information we hold about you
- Correction: Request that we correct inaccurate or incomplete information
- Deletion: Request that we delete your personal information, subject to legal retention requirements
- Opt-out of email marketing: Unsubscribe at any time using the link in any email or by contacting us. Transactional and service emails may continue.
- Opt-out of SMS: Reply STOP to any text message or contact privacy@thegrowthlayer.com
- Opt-out of ad targeting: Contact us to remove your email from custom audience lists on advertising platforms
- Data portability: Request your data in a structured, portable format where technically feasible
- Object to processing: Object to processing based on legitimate interests, including direct marketing
- Restrict processing: Request we restrict processing while accuracy or legitimacy is disputed
California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA): the right to know what personal information is collected and how it is used; the right to delete; the right to correct; the right to opt out of the sale or sharing of personal information; and the right to non-discrimination for exercising your rights.
We do not sell personal information. Use of your email address to build custom audiences on advertising platforms for our own campaigns does not constitute a “sale” under the CCPA. To opt out of this use, email privacy@thegrowthlayer.com.
To submit a California rights request, email privacy@thegrowthlayer.com with the subject line “California Privacy Request.” We will respond within 45 days. You may submit up to two requests per 12-month period. We will not discriminate against you for exercising your rights.
To exercise any of these rights, email privacy@thegrowthlayer.com. We may verify your identity before processing your request. We will respond within 30 days (45 days for California requests).
12. Third-Party Links
Our site may contain links to third-party websites. We are not responsible for their privacy practices. When you leave our site, this policy no longer applies. Review the privacy policies of any third-party sites you visit.
13. Changes to This Policy
We may update this policy periodically. Changes will be posted here with a new effective date. For material changes, we will notify you by email (if you are a subscriber) or by prominent notice on our site. Continued use of our site after changes are posted constitutes acceptance.
14. Contact
For privacy questions, rights requests, or to report a concern:
The Growth Layer LLC
privacy@thegrowthlayer.com
For California rights requests, include “California Privacy Request” in the subject line.
Legal
Privacy Policy
Last updated: June 2026
The Growth Layer (‘we,’ ‘us,’ or ‘our’) is committed to protecting your personal information. This Privacy Policy describes how we collect, use, and share information when you use our website and services.
Information we collect
We collect information you provide directly, including name, email address, company name, and any other information submitted through our contact forms or services. We also collect usage data, device information, and analytics data through standard web tracking tools including cookies and similar technologies.
How we use your information
We use the information we collect to provide, maintain, and improve our services, communicate with you about services and updates, analyze usage patterns to enhance user experience, and comply with legal obligations. We do not sell your personal information to third parties.
Data retention and security
We retain your information for as long as necessary to provide services and comply with legal requirements. We implement industry-standard security measures to protect your data. No method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.
Your rights
You have the right to access, correct, or delete your personal information. You may opt out of marketing communications at any time by clicking the unsubscribe link in any email or contacting us directly at privacy@thegrowthlayer.com.
Contact
Questions about this policy? Contact us at hello@thegrowthlayer.com.