Privacy Policy

Introduction to Our Privacy Policy At Silverstar Growth Labs (“Silverstar Growth Labs,” “we,” “us,” or “our”), we are committed to protecting your privacy. We provide B2B marketing and demand generation solutions to businesses worldwide. Our services include Demand, Advertising, Data, Web, Outreach, Events, and Studio. We respect your personal data and strive to protect it. Personal data includes details like your name, contact information (email, physical address, phone number, IP address), professional or employment information, and interactions with our website or emails. In this Privacy Policy, we explain the types of personal data we collect, why we collect it, the lawful bases for data collection, how we use it, and your rights regarding your data. Getting in touch If you have questions about this policy or your personal data, contact us at: Email: dpo@sgrowthlabs.com

1.Scope This policy explains when and how we collect and use your personal data, including:

• When you purchase or use our Products and Services, or visit our website or platform.
• Business Contact Information (BCI) like name, job title, business email, and business phone number that we collect from you, the public domain, or third-party sources.

Applicability: This policy applies to individuals who visit our websites (Visitors), individuals acting on behalf of a business entity (Client Representatives), and individuals in their professional capacity (Professionals). This policy does not address personal data provided by our clients and other third parties or the privacy practices of our clients and other third parties. If you have questions about this policy, contact us at dpo@sgrowthlabs.com

2. Personal Data We Collect and How We Collect It

We collect different types of personal data depending on how you interact with us. This includes: Information You Provide Directly When you interact with our website or platform, request content (like white papers), subscribe to our newsletters, fill out a contact form, or comment on blogs or community pages, we may ask for your:

• Name, company, job title, business email address, and business phone number
• Areas of interest

You can also log in to our website using your social media accounts (e.g., Facebook, X, LinkedIn). We may also collect information when you respond to surveys (either online or by phone). Information We Receive from Public Sources We collect Business Contact Information (BCI) from third-party sources, including public databases and partners. This may include:

• Name, contact information (business email, business phone number), job titles, and location

We use this data to enhance the services we provide to our customers. Automatically Collected Information We may automatically collect information about your visit to our website, including:

• Your IP address, browser type, operating system, pages viewed, links clicked, preferences and browsing patterns, and referring URL
• Cookies and other tracking technologies may also collect information about your interactions with emails we send, like whether you open them or click on links

Telemarketing and Communications We may use your phone number to contact you via telemarketing, which may include promotional calls or offers related to our products and services. By providing your phone number, you consent to receive such communications. You can opt-out of receiving telemarketing calls at any time by following the instructions provided during each call or by contacting us directly. We respect your preferences and will ensure that any telemarketing communications comply with applicable laws and regulations. You can manage your cookie preferences through your browser settings. For more information, see Section 11 Our Use of Cookies, Pixels, VID Tags and Other Tracking Technologies.

3. How We Use Personal Data

We use personal data in several ways to improve our services and communicate with you:

• To Fulfil Your Requests We use your data to respond to your inquiries, process your purchases, and provide the services you’ve requested.
• To Personalize Your Experience We use your data to create a personalized profile based on your interests and preferences. This helps us provide tailored recommendations, assistance, and guidance while you visit our website.
• For Marketing Communications We may use your email or phone number to send updates, surveys, newsletters, promotions, and service-related SMS/text messages.

For SMS/Text Messaging in Particular By providing your mobile number and opting in, you agree to receive SMS/text messages from us regarding your inquiries, account updates, and marketing communications. Message frequency may vary. Message and data rates may apply. You may opt-out at any time by replying STOP to any message. For help, reply HELP or contact us at dpo@sgrowthlabs.com. To Provide Accurate Business Data We offer our customers access to accurate business data, such as Business Contact Information (BCI), to help them target decision-makers and promote their services more effectively.

• To Improve Our Website We analyze how visitors use our website to better understand user behavior and improve site performance. You can manage your preferences for tracking technologies through your browser settings.
• For Research and Development We use personal data to conduct tests, research, and development to improve our products and services.
• For Business Transactions In the event of a merger, acquisition, or sale of assets, your personal data may be included in the transferred assets. We will notify you as required by applicable law if this occurs.
• For Other Purposes If we need to use your data for purposes not described above, we will contact you for your permission.

4. How We Share Your Personal Data

We may share your personal data in the following ways:

• Within SGL Your personal data may be shared within Silverstar Growth Labs Group (SGL) subsidiaries and affiliates. This could involve sharing data outside of the EEA and the UK. We ensure that all SGL entities comply with data privacy laws.
• Other Website Visitors If you post comments on public areas of our website (like blogs), your comments and identity may be visible to all users. This does not apply to personal data shared through “Contact Us” inquiries.
• Upon Your Request or Instruction We may share your data with SGL subsidiaries, affiliates, or specific business customers as part of your request (e.g., when you complete surveys or request content).
• Service Providers We share personal data with trusted third-party vendors and service providers who help us deliver our services. These providers are only allowed to use your data for specific tasks on our behalf.
• Customers and Partners We may share your data with customers and business partners to offer you the services you have requested or have opted-in for, including third-party tools or software integrated into our website.
• Business Contact Information We may share Business Contact Information with our clients for their B2B marketing and sales purposes. This information may include name, company, job title, business email and business phone number.
• Business Transfers If we merge with, are acquired by, or transfer assets to another company, your personal data may be part of the assets transferred.
• In Response to Legal Requests We may disclose your data to comply with legal requirements, such as court orders, subpoenas, or other legal processes.
• To Protect Us and Others We may share your data if it’s necessary to investigate or prevent illegal activities, fraud, safety threats, or violations of our Terms of Use or Privacy Policy.

5. Third-Party Links

Our sites may contain links to other websites, social media, apps, or online locations (“Third-Party Sites”). We are not responsible for the content, privacy practices, or services of these Third-Party Sites. Any information you share on a Third-Party Site is governed by its own privacy policy, not ours. Links to other websites do not imply an endorsement or affiliation. We recommend reviewing the privacy policies of any Third-Party Sites before engaging with them. Additionally, our sites may include social media widgets that can share information about your interaction with our pages, even if you don’t click on them. These widgets may transmit details like your browser type, IP address, and the URL of the page you’re on. We encourage you to review the privacy policies of social networks or third-party services to understand what information they collect and how they use it.

6. Lawful Basis for Processing Your Information

We process your personal data based on the following legal grounds: Your Consent. In some cases, we need your consent to use your personal data, like when we send marketing emails to residents of the European Economic Area (EEA). If you ever want to withdraw your consent, you may Opt-out. You can also (i) choose not to provide consent for cookies or pixels, (ii) close your account, or (iii) unsubscribe from our communications. Check out “Your Rights and Choices” below for more details. To Fulfil a Contract. We may need to collect and use your personal data to meet our obligations under our agreement with you, taking into account any opt-out preferences you’ve set. Legitimate Interests. We may use your information for our legitimate business interests, such as improving our website, technology, and services. This includes processing information on behalf of our clients who also have legitimate reasons for doing so. We may use technical information and personal data for marketing purposes, as long as we respect your preferences and comply with applicable laws. Legal Compliance. We may need to use your personal data to meet legal requirements and obligations.

7. Your Choices Regarding Personal Data Use Your Rights: If you are located in the EEA or the United Kingdom, you have the right to access, correct, or delete your personal data, request data portability, and object to processing based on legitimate interests. You also have the right to lodge a complaint with a supervisory authority.

CCPA Rights: California residents have the right to know what personal data we collect, request deletion of their data, and opt-out of the sale or sharing of their personal data. You can exercise these rights. Send an email to dpo@sgrowthlabs.com to submit a Data Subject Rights Request. General: We may send you periodic emails. You can opt-out by following the instructions in the email, but please note it may take some time to process. Some messages, like transactional or legal notices, cannot be opted out of. Rights You May Have Based on Your Location Visiting Our Website from Outside the United States If you are visiting our website from outside the U.S., your data may be transferred, stored, and processed in the U.S., U.K., India and the Philippines, where our servers are located. Data privacy laws in these countries may differ from those in your country. Individuals in the European Economic Area (EEA) or United Kingdom This section applies to individuals in the EEA or U.K. or those interacting with our entities in the EU or U.K. For questions, contact us on dpo@Sgrowthlabs.com Basis for Processing Personal Data of EEA and UK Individuals We process your personal data based on:

• Consent: For marketing communications (you can withdraw consent anytime).
• Contractual Relationship: To fulfil obligations if you have a direct relationship with us
• Legitimate Interests: To conduct market research, offer content, improve services, and for business purposes.
• Legal Obligations: To comply with laws within the EEA or U.K.

We may transfer personal data outside the EEA or U.K. under applicable legal measures. Rights for EEA and UK Individuals You have the right to:

• Access, correct, or delete your personal data.
• Withdraw consent without penalty.
• Request data portability.
• Restrict processing or request deletion in certain situations.
• File complaints with a supervisory authority (ICO for the U.K., or your local authority in the EEA).

To exercise these rights, contact us on dpo@sgrowthlabs.com. California Residents Shine The Light Law Under California’s “Shine The Light” law (California Civil Code § 1798.83), California residents can request information about the types of personal data disclosed to third parties for direct marketing purposes. To request this, email us at dpo@sgrowthlabs.com with “California Shine The Light Request” in the subject line, and include your mailing and email addresses. The California Consumer Privacy Act (CCPA) The CCPA gives California residents specific rights regarding their Personal Data. These include:

• Opt-out: You can opt-out of the sale or sharing of your Personal Data with third parties.
• Right to Know: You can request details about:
  • What Personal Data we have about you.
  • The categories of Personal Data we’ve collected.
  • Where we collected your data from.
  • What data we’ve sold, shared, or disclosed, and to whom.
• Right to Delete: You can request the deletion of your Personal Data, with some exceptions.
• Right to Correct: You can request corrections to any inaccurate Personal Data.
• Limit Use of Sensitive Personal Data: You can limit how we use your sensitive personal data (except for job applicants and employees).

Note: SGL does not collect sensitive personal data for most California residents, but this applies to job applicants and employees. Additionally, the CCPA prohibits discrimination if you exercise these rights. Exercising Your CCPA Rights

• Opt-out: To opt-out of the sale or sharing of your data, complete our online form or email us.
• Request to Know, Delete, or Correct: Send an email to dpo@sgrowthlabs.com to submit a Data Subject Rights Request.

We will acknowledge receipt of your request within 10 days and provide a response within 45 days. In some cases, we may extend this period by an additional 45 days, and we’ll inform you if that happens. Requests from U.S. States Other Than California Some U.S. states have laws similar to the CCPA. While these laws may exclude certain types of Personal Data, we will honor requests from residents of any U.S. state (except for job application or employment-related data) to:

• Know
• Delete
• Correct

To make a request, please send an email to spo@sgrowthlabs.com, to submit a Data Subject Rights Request.

8. Children’s Privacy Our website is not intended for children under 16, and we do not knowingly collect their personal data. If we discover that we have collected personal data from a child under 16 without appropriate consent, we will delete that data as required by law. If you believe we may have collected such information, please contact us immediately at dpo@sgrowthlabs.com.
9. How Long We Keep Your Personal Data

We retain your personal data only for as long as necessary to fulfil our business purposes and comply with legal obligations. The retention period depends on factors such as:

• The reason for collecting the data
• Whether the data is required to provide our services
• Whether retaining the data is necessary for legal or business purposes, such as resolving disputes, enforcing agreements, or conducting audits.

We also take reasonable steps to protect your personal data. We implement administrative, physical, and technical measures to safeguard your data. Where applicable, we may obtain written commitments from third parties who access your data, ensuring they use safeguards similar to ours. However, please note that no internet or email transmission is completely secure, and we cannot guarantee absolute security. 10.Our Use of Chatbots Our website might feature a chatbot in the near future, allowing you to interact with us in real time.

• When you use the chatbot, any information you provide, such as your name or IP address, may be collected. We may also store a transcript of your interaction.
• This data helps us process your requests, improve our services, and enhance our responses. By using the chatbot, you consent to the collection and storage of your interactions.

11. Our Use of Cookies, Pixels, VID Tags and Other Tracking Technologies

We use cookies and other tracking technologies to collect information about how you use our website. This helps us improve your experience, but we may also combine this data with other personal data we collect. Please note that our systems do not respond to browser “do-not-track” requests. However, you can manage or disable cookies as explained below. What Are Cookies and How Do They Benefit You? Cookies are small text files placed on your device when you visit a website. They help websites remember you by storing information about your visit.

• Cookies on our Website don’t store personal data like names, addresses, or phone numbers.
• They improve your browsing experience by remembering preferences and enhancing site functionality.

For more details about cookies, visit https://www.allaboutcookies.org/. What Information is Stored by Cookies? A cookie typically stores:

• The website it came from
• How long it will stay on your device
• A unique identifier (usually a randomly generated number)

Granting Permission for Cookies If your browser is set to accept cookies, we assume you consent to our use of cookies. If you don’t want cookies, you can disable them in your browser settings, but this may affect the website’s functionality. Types of Cookies We Use

1. Website Function Cookies: These help the website function properly (e.g., remembering your login details).
2. Session Cookies: Temporary, removed when you close your browser.
3. Persistent Cookies: Remain on your device until deleted or they expire.
4. Social Media Cookies: These allow easy sharing of content on platforms like Facebook and Twitter. Their privacy implications depend on your social media settings.
5. Analytics Cookies: We use tools like Google Analytics to understand website usage and improve user experience. Data is anonymized, and we don’t share personal data with these analytics tools.
6. Third-Party and Advertising Cookies: We use these cookies to deliver relevant ads and content based on your interests. Third-party vendors, such as Google and AdRoll, place these cookies on your device. You can opt-out of these ads on their websites.

Turning Off Cookies You can disable cookies through your browser settings. However, please note that this may impair the performance of the website. Local Storage Objects (Flash LSOs) We may also use Flash LSOs to store preferences and personalize your visit. These can’t be managed through your browser settings, but you can manage them using Adobe’s Flash Player Help Page. Pixels us We use pixels to track website usage, manage content, and measure engagement. These are also used in emails to track open rates and response.  The data collected through pixels may be combined with other information we have including your marketing preferences and information that you have provided to us when filling out forms.  We do not sell or share this information with third parties for their independent marketing purposes. VID Tags A VID Tag (Visitor Tag) is a unique identifier assigned to you or your device when you visit or interact with our website or platform that is stored in a cookie or other local storage.  When you make subsequent visits to our website or platform, the website or platform uses the VID to associate actions with the same anonymous user profile.

12. Artificial Intelligence and Automated/AI-powered Marketing Processing

We are committed to ensuring responsible use of artificial intelligence and automation. We use AI and machine-learning technologies to support our demand generation activities, lead-scoring, segmentation, content personalization and outreach activities. These systems analyze data such as your business contact information (name, title, company, email), activity on our digital properties (pages visited, content downloaded, emails opened/clicked), historical engagement data, and third-party enrichment data.  Our systems do not infer sensitive personal information and are periodically tested for accuracy and bias to ensure fair outcomes. We do not process sensitive attributes of personal data. The lawful basis for this processing includes our legitimate interest in carrying out effective B2B marketing and outreach, coupled with your consent where required by applicable law. We have conducted a balancing test that confirms our interests do not override your rights and freedoms. We engage third-party service providers and AI vendors under data processing agreements and require them to maintain industry standard security, confidentiality, and accuracy practices. AI-derived profiles, scores, and segmentations are retained in accord with Section 9 How Long We Keep Your Personal Data. Automated Decision-Making. We do not use AI to make decisions that have legal or similarly significant effects on individuals without appropriate human oversight. You have the right to object to processing for our direct marketing purposes, to request access, correction or deletion of your personal data, and to withdraw any consent given. Please see Section 7 Your Rights Regarding Personal Data Use for more information. In transferring data across borders for AI processing, we employ standard contractual clauses and implement appropriate technical and organisational safeguards.

13. Changes to This Policy

We may update this policy periodically. If significant changes are made, we will notify you by email or post a notice on our website. The updated policy will become effective on the “Effective Date” listed at the top of this page.