PRIVACY POLICY

Last updated: 2026

1. Introduction
   This Privacy Policy describes how Growithcontent collects, uses, stores and protects the personal data of users of the website growithcontent.com and of individuals who contact us to request or receive digital marketing and creator management consulting services (the “Services”).

This notice is provided pursuant to Articles 13 and 14 of EU Regulation 2016/679 (“GDPR”) and the Italian Privacy Code (Legislative Decree 196/2003 as amended by Legislative Decree 101/2018).

2. Data Controller
   The Data Controller is:
   SBM CONSULTING LLC

Registered address: 30 N Gould St 42050, Sheridan, WY 82801, United States
EIN: 32-0857034
Email: sbmconsultingllc@outlook.it

For any questions regarding this Policy or to exercise your rights, you may contact the email above.

3. Types of data collected

3.1 Data directly provided by the user
Through the contact form on the website we collect:
• Full name
• Email address
• Service of interest (selected from dropdown menu)
• Project description or message

Through email or WhatsApp communications:
• Any information voluntarily provided by the user

When a contractual relationship for Services is established, we also collect:
• Billing data (company name, VAT number or tax code, billing address)
• Operational contact details (phone number, internal contacts)
• Authorized access credentials to client social media, advertising and analytics platforms, only when explicitly authorized and strictly for contractual purposes
• Content, materials and information required to deliver the Services

3.2 Automatically collected data during navigation
When you visit the website, we may automatically collect:
• IP address (anonymized for statistical purposes where applicable)
• Browser type and version
• Device type and operating system
• Pages visited, time spent, referring URL
• Date and time of access
• Approximate geographic location (country or region level)

These data are collected via cookies and similar technologies as described in the Cookie Policy.

4. Purpose and legal basis of processing
   Personal data are processed for the following purposes and legal bases:

• Responding to contact and consultation requests, legal basis: pre contractual measures, Article 6.1(b) GDPR
• Service delivery, legal basis: contract performance, Article 6.1(b) GDPR
• Accounting and tax compliance, legal basis: legal obligation, Article 6.1(c) GDPR
• Newsletter and marketing communications, legal basis: consent, Article 6.1(a) GDPR
• Statistical analysis of website usage, legal basis: consent or legitimate interest depending on case, Article 6.1(a) or 6.1(f) GDPR
• Marketing cookies and profiling, legal basis: consent, Article 6.1(a) GDPR
• Legal defense and fraud prevention, legal basis: legitimate interest, Article 6.1(f) GDPR

5. Processing methods
   Data are processed mainly using electronic tools by authorized and trained personnel, with appropriate technical and organizational measures pursuant to Article 32 GDPR.

No automated decision making processes producing legal or significant effects are used.

6. Data retention periods
   Data are stored only as long as necessary for the purposes for which they are collected, and in any case:

• Unconverted contact requests: 12 months
• Client data: duration of the contractual relationship plus 10 years after termination for legal and tax obligations
• Marketing contacts and newsletter: until consent is withdrawn or after 24 months of inactivity
• Website analytics data: 14 months
• System logs: 30 days
• Invoices and tax documents: 10 years

After retention periods expire, data are deleted or irreversibly anonymized.

7. Data disclosure
   Data may be shared with:

• Service providers acting as data processors under Article 28 GDPR, including:
• Hosting providers
• Analytics providers such as Google Analytics
• Email service providers such as Google Workspace or Microsoft 365
• CRM and project management tools such as Notion and Slack
• Billing and accounting systems
• Accountants and tax consultants

• Public authorities when required by law
• Legal and tax advisors under confidentiality obligations

Personal data are never sold or shared for independent commercial purposes.

An updated list of data processors is available upon written request.

8. International data transfers
   Some providers such as Google or Meta may process data outside the European Economic Area. In such cases, appropriate safeguards are applied under Chapter V GDPR, including:
   • Standard Contractual Clauses approved by the European Commission
   • Adequacy decisions where applicable
   • Additional technical and organizational measures where required

9. Rights of the data subject
   Under Articles 15 to 22 GDPR, you have the right to:
   • Access your personal data
   • Rectify inaccurate data
   • Erase data where applicable
   • Restrict processing
   • Data portability
   • Object to processing based on legitimate interest
   • Withdraw consent at any time without affecting prior lawful processing

Requests can be sent to sbmconsultingllc@outlook.it and will be handled within 30 days, extendable to 60 days if necessary.

You also have the right to lodge a complaint with a supervisory authority, including the Italian Data Protection Authority.

10. Data security
    We implement appropriate technical and organizational measures including:
    • TLS encryption for all communications
    • Access control and authentication systems
    • Encrypted backups
    • Restricted access to authorized personnel only
    • Confidentiality obligations for staff and partners

In case of a personal data breach, we will notify the relevant authority within 72 hours where required and, when necessary, inform affected individuals without undue delay.

11. Minors
    Services are not intended for individuals under 16 years of age. We do not knowingly collect data from minors. Any such data will be deleted if identified.

12. Changes to this Privacy Policy
    We may update this Privacy Policy over time. The last updated date indicates the most recent revision. Significant changes will be communicated via email or website notice.

13. Contact
    For privacy related inquiries: sbmconsultingllc@outlook.it
    SBM CONSULTING LLC
    Website: growithcontent.com