Growthflicks Privacy Policy v.2.0.

- effective from October 9, 2025

Please note: While most of our users would likely prefer a shorter privacy notice, current laws and regulations require us to offer a lot of information on our processing operations. We have thereby endeavoured to offer summarised snapshots of the most relevant information under certain sections of this notice. Feel free to read the short section summaries provided at the beginning of most sections or read the full legally binding text below each summary.

We truly hope that you find the contents contained herein understandable. Should you require a "clean" version of this notice as well as any additional information or clarifications regarding the processing of your personal data and the use of our products and services, feel free to reach out to us at [email protected].

For clarity: we do not collect or otherwise process any special category data when providing the Growthflicks service, and we store all collected data in encrypted form both in transit and at rest.

WE DO NOT TRAIN ANY MODELS ON GOOGLE USER DATA. This commitment applies to every environment and feature within Growthflicks, including any AI-powered capabilities.

1. Introduction

This privacy policy serves as a notice to individuals under Article 13 of the General Data Protection Regulation (GDPR) regarding the processing of personal data by 5 ELEMENT d.o.o., ustvarjanje sinergij as well as its subsidiaries, and outlines how personal and other data is processed in connection with the Growthflicks service and the corresponding https://growthflicks.com/ website as well as other company-wide operations and processes, as further outlined below (hereinafter: privacy notice or notice).

All California residents that visit our website, use our products or otherwise interact with our organisation are kindly asked to observe section 5 of this notice which has been prepared in accordance with the California Consumer Privacy Act.

1.1. Information on the controller of your personal data

Summary: Information on us (i.e. the data controller responsible for your personal data) and where we, our EU representative or our dedicated Data Protection Officer can be reached.

5 ELEMENT d.o.o., ustvarjanje sinergij,

Jurčičeva ulica 18,

1295 Ivančna Gorica,

Slovenia,

company reg. no.: 2214172000,

VAT ID no.: SI 30673585,

LEI: 485100CJQLUIDSDDS972,

email: [email protected]

(hereinafter: we, us, 5 ELEMENT, the controller, organisation or company)

Our data protection officer has been appointed and is reachable at [email protected].

1.2. Use and applicability of this privacy notice

Summary: This privacy notice is applicable if you visit our websites, use the Growthflicks service or otherwise interact with our company in a way where we receive or otherwise process your data as mentioned under sections 2 and 3 of this notice. If you are a resident of California, please see section 5. In the event of substantial changes to this notice, we will notify you accordingly via email or through our website (depending on the importance of the change).

2. Data processing activities that relate to our websites, communication, sales and delivery of our products, our general marketing and other company operations

Summary: The following is an overview of when we process your personal data, what personal data we process, why we process said data, what underlying legal basis allows us to do this and how long we keep your data in each case. This section refers to situations where you visit our websites, communicate with us, buy from us, or when we perform our general marketing and other activities. We do not sell personal data of any individuals.

2.1. Visiting and using our websites

2.1.1 Visiting our website involves the placing of necessary cookies

Summary: We automatically place necessary cookies on your device when you visit our website. These cookies are necessary so that our website may be displayed and function properly. These cookies do not typically reveal any information about your browsing habits and preferences (see our dedicated Cookie Policy to learn more).

When: When you visit our website, we automatically place necessary cookies on your device.

Data: Necessary cookie data which typically only reveals technical information about your device (see our Cookie Policy to learn more).

Purpose: Necessary cookies are essential for the correct functioning of our website and enable key functions like page navigation, display features, page responsiveness, etc. (see our Cookie Policy to learn more).

Legal basis: We are legally permitted to place necessary cookies on your device without consent.

Data retention: Necessary cookie data can either be stored for the duration of your browsing session or longer (see our Cookie Policy to learn more).

2.1.2 Consenting to our use of analytical cookies

Summary: When you visit our website, we may place analytical cookies on your device. These cookies are provided to us by our service providers such as Alphabet Inc. (i.e. Google) and others, whereby they make use of automated technologies to collect and analyse information which includes personal data (such as your IP address) to understand how you use our website in order to tailor our site user experience or even increase the effectiveness of our future ad campaigns. These cookies might reveal information about your browsing habits and preferences (see our Cookie Policy to learn more).

When: When you visit our website and click the relevant button in our cookie pop-up.

Data: The information we obtain in this manner may include your device's IP address, identifiers associated with your devices, the types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of website visits (see our Cookie Policy to learn more).

Purpose: Our analytical cookies help us understand how visitors interact with our websites by collecting and reporting usage information. The intention is to improve features, evaluate and optimise the website user experience, and potentially improve the effectiveness of our marketing (see our Cookie Policy to learn more).

Legal basis: Where required by applicable law (e.g. if you are a resident of the European Economic Area), we will obtain your consent before placing analytical cookies on your device.

Data retention: Analytical cookie data can either be stored for the duration of your browsing session or longer (see our Cookie Policy to learn more).

2.1.3 Consenting to our use of marketing cookies for online tracking and interest-based advertising

Summary: When you visit our website, we may also place marketing cookies on your device. These cookies are provided to us by our service providers such as Alphabet Inc. (i.e. Google), Meta Platforms Inc. (i.e. Facebook) and others, whereby these cookies make use of automated technologies to collect and analyse different information, including personal data (such as your email, IP addresses, search history, clicks, preferences, interests) for targeted advertising purposes across the web. These cookies reveal information about your browsing habits and preferences (see our Cookie Policy to learn more).

When: When you visit our website and click the relevant button in our cookie pop-up.

Data: Data collection takes place both on our website and on third-party websites where our providers' cookies, web beacons, pixels and other similar technologies have been placed on your device and where your inferred interests, browsing context, demographic data as well as other online activities over time have been collected through automated means (see our Cookie Policy to learn more).

Purpose: Our marketing cookies are used to track visitors across different websites. The intent is to increase the effectiveness of our ads by enabling target- and interest-based advertising on other online platforms, websites and ad networks (i.e. when you use Google search, Facebook, etc.) (see our Cookie Policy to learn more).

Legal basis: Where required by applicable law (e.g. if you are a resident of the European Economic Area), we will obtain your consent before placing marketing cookies on your device.

Data retention: Please see the information for each individual cookie provider in our Cookie Policy.

2.2. Communication, sales and delivery of our products

2.2.1 When reaching out to us both on and off our websites

Summary: When you reach out to us (e.g. by sending an email to an address that belongs to us, etc.), we shall process any data you might share (or have shared with us in the past) in order to respond to you or fulfil your request.

When: When you choose to reach out to us or contact us (i.e. by sending an email to an address that belongs to us, submitting a question through our chat module, reaching out to us through our official email channels, our social media platforms, or in communication with our employees/agents or via other means).

Data: We may process any data/information you disclose during your purchase (such as your name, email address, billing address, shipping address, products ordered and order number) or which we might already have and require to formulate our response/solve your issue.

Purpose: In order to respond to emails, messages, formal inquiries, proposals, support, troubleshooting and other inbound communication.

Legal basis: We carry out these processing activities because processing might be necessary for the performance of a contract to which the person reaching out to us is a party (e.g. if you have bought a product from us and reach out to us for product related information) or in order to take steps at the request of the data subject prior to entering into a contract (e.g. if you reach out to us with questions about our products prior to placing an order) or on the basis of our legitimate interests.

Data retention: We typically do not keep communication data after responding to you. An exception to the aforementioned can be made if messaging or other communication had been performed through the use of a dedicated service (i.e. email, chat module, etc.), whereby we may keep data in such systems for up to 3 years after having received it.

3. Data processing disclaimer in relation to AI services

Please note: While the vast majority of all inputs used in connection with the Growthflicks service contain no personal data, we take privacy seriously and have prepared this notice and our policies to specifically address cases where our service might have inadvertently processed information on an identifiable natural person Please keep in mind that each user is ultimately the one responsible for any lawful use of personal or other data (e.g. copyright) that is used in connection with the service and may be considered as an individual "data controller" in relation to any personally identifiable information contained in the inputs which are entered into the service by the user and which the service offers as its output for the individual use by the user.

Each user is ultimately also responsible for storing, sharing, posting or otherwise using any service generated outputs online or elsewhere and for following local privacy and other applicable (e.g. copyright) laws.

We do not sell personal data of any individuals.

4. Additional general information

4.1. How we might obtain your personal data

Summary: We use different methods to collect data from and about you, including: direct interactions, automated technologies or interactions, third parties or publicly available sources.

Direct interactions

You may give us information about you by filling in forms or by communicating with us by phone, email or otherwise. This includes information you might provide when creating an account in order to use our service or when obtaining a licence to use our service, subscribe to our newsletter, search for a product online with a tracking cookie from our partners installed on your device, place an order through our website or its check-out module, enter one of our competitions, promotions or surveys and when reporting a problem with our website or a bug in our service.

Automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your device, browsing actions and patterns by using cookies and other similar technologies as specified above in section 2 of this notice and in our Cookie Policy.

Third parties or publicly available sources

We may receive information about you if you visit other websites that place tracking cookies from our partners on your device (see our Cookie Policy to find out more). You may also post some of your information publicly online.

4.2. What rights do you have in connection with your personal data and how can you exercise them?

You can contact us at any time and without hesitation at [email protected] in connection with this notice or regarding the processing of your personal data by our organisation and our processors/service providers.

You can also contact us at the email mentioned above in order to send us your specific requests and for exercising your other rights which relate to your personal data and applicable local legislation or the GDPR. If we have reasonable doubts concerning your identity, we may request additional information to verify your identity.

As a data subject of the EEA, the GDPR gives you the opportunity to exercise the following rights with our organisation as the controller of your personal Data:

  • Right of access
  • Right to rectification
  • Right of objection
  • Right to data portability
  • Right to restrict data processing
  • Right of erasure ("right to be forgotten")
  • Right to refuse or withdraw consent
  • Automated decision-making
  • Right to lodge a complaint with a supervisory authority

5. Privacy information for California residents

5.1. Applicability of this section

If you are a California resident (as defined in section 17014 of Title 18 of the California Code of Regulations), California law requires us to provide you with some additional information regarding your rights with respect to your "personal information" as defined in the CCPA.

5.2. Information on whether we disclose or sell personal data of CA residents

Summary: In the preceding twelve (12) months we have not sold or disclosed any personal information prior to the last update that had been made to this notice.

We have not disclosed any personal data in the last 12 months. We only disclose your personal data to third party processors/service providers in order to achieve the purposes of the processing activities described in sections 2, 3 and point 4.4 of this notice or when you have consented to such disclosure, whereby such third-party processors/service providers have concluded a data processing agreement with us (or offered similar safeguards) to ensure your rights are respected.

5.3. Information on the rights of CA residents

Summary: The CCPA provides Californian residents with the following rights: Right to know, Right to delete, Right to opt out, The right to non-discrimination.

Right to know (i.e. request disclosure of any personal information we have collected about you).

You have the right to request the disclosure of the categories of personal information we have collected from you, along with the categories of sources from which they have been collected, the purpose of their collection, the categories of third parties with whom we have shared your personal information ("Categories Report"), and the specific pieces of personal information that have been collected ("Specific Pieces Report").

Right to delete (i.e. request deletion of any personal information that we have collected from you).

After we have verified your request to delete your personal information, we shall delete it from our servers/records and direct any of our processors/service providers to delete your personal information from their servers/records, except when certain exemptions from the relevant parts of the CCPA are applicable.

Right to opt out (of the sale of your personal information).

You may request that we stop selling your personal information, whereby this is currently not applicable as we do not currently sell any personal information.

The right to non-discrimination (when exercising your CCPA rights).

We will not discriminate against you in any manner prohibited by applicable law for exercising your CCPA rights (as listed above).

6. Document version and updates

Version and date of the last update of this notice

The text of this notice represents version 2.0. of this document.

Please reach out to us at [email protected] in order to receive the previous version of this document.

This notice was last updated on October 9, 2025.

For any questions about this Privacy Policy, please contact us at [email protected]