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GrowthCues Privacy Policy

Last updated January 13, 2026

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in the singular or in the plural.

Definitions

For the purposes of this Privacy Policy:

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.

  • Agreement refers to these Terms and Conditions, including any other attachment, addendum, exhibit, or order form(s), by which the Parties have agreed on Customer’s right to use the Service.

  • Company (referred to as either “the Company”, “We”, “Us”, “Our”, “GrowthCues”, or “Arvoan” in this Agreement) refers to Arvoan Ltd, Alingsåsinkatu 12 A 1, 10300 KARJAA, Finland.

  • End Users are those persons who access the Services using the Customer’s account.

  • Feedback refers to any suggestion or idea for modifying any of the Company’s products or services, or other intellectual property, including without limitation all intellectual property rights in any such suggestion or idea.

  • Party means individually either Customer or the Company, as the case may be, and Parties shall mean Customer and the Company jointly.

  • Personal Data is any information that relates to an identified or identifiable individual.

  • Service means the software provided by Arvoan Ltd, including any updates, improvements, and changes to it, made available to customers with software as a service licensing and delivery model.

  • Terms and Conditions (also referred to as “Terms”) mean these Terms and Conditions that form the entire agreement between You and Arvoan regarding the use of the Service.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • You (referred to as either “You” or “Customer”) means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

  • Website refers to websites and their content owned by Arvoan, under any website domain owned or controlled by Arvoan.

Data Controller and Processor Status

1. When We act as a Data Controller: Arvoan Ltd is the Data Controller for the Personal Data You provide to us directly (e.g., your account registration, billing information, and direct communications with support).

2. When We act as a Data Processor: For the data contained within Your connected Data Warehouse (e.g., Snowflake, BigQuery) that our Service processes to generate metrics and scores ("Service Data"), You are the Data Controller and Arvoan Ltd is the Data Processor. We process this data solely on Your behalf and in accordance with Your instructions (i.e., the configuration of the Service).

Contact Details: - Name: Arvoan Ltd

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data (Admin Data)

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You ("Admin Data"). Personally identifiable information may include, but is not limited to:

  • Email address

  • First name and last name

  • Billing and payment information (processed via our payment provider Stripe)

  • Profile information, including but not limited to, Your photo/avatar, last login time, login IP address, or number of logins

  • Usage Data

Customer Warehouse Data

In order to provide the Service, we access specific tables within Your Data Warehouse. While this data remains under Your ownership, we process it to generate metrics, journeys, and predictive scores. This data may include identifiers (User IDs, Account IDs) and behavioral events of your own end-users. We process this data strictly to provide the Service and do not use it for our own independent marketing purposes.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, activities taken by You while using the Service, and other diagnostic data.

Rudderstack: We use Rudderstack to collect and route first-party usage data (such as clicks, page views, and feature usage) to our internal data warehouse (Google BigQuery). This data helps us understand how our Service is used and allows us to improve the user experience.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with GrowthCues through behavioral metrics, heatmaps, and session replay to improve our products. Usage data is captured using first and third-party cookies and other tracking technologies to determine online activity while using GrowthCues. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Google Ads and Google Analytics

We use Google Ads and Google Analytics to track user engagement with our product webpage and to improve our products. These services collect and process user data in accordance with their respective privacy policies.

We offer you the option to consent to the use of these tools through clear opt-in mechanisms provided on our webpage, such as cookie banners and consent management tools. You can choose to accept or decline the use of Google Ads and Google Analytics, and you can modify your preferences at any time.

You can find more information about how Google collects and processes your data here:

Legal Basis for Processing Personal Data (GDPR)

We process Personal Data under the following legal bases:

  • Performance of a Contract: We process Your Personal Data and Warehouse Data to provide the Service You subscribed to.
  • Legitimate Interests: We process Usage Data to improve our Service, ensure security, and prevent fraud.
  • Consent: We process data via cookies (Google/Microsoft) and send marketing emails only with Your explicit consent, which You can withdraw at any time.
  • Legal Obligation: We retain invoice and billing data to comply with Finnish accounting and tax laws.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including monitoring the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service.
  • For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the services You have purchased.
  • To contact You: To contact You by email regarding updates, security alerts, or informative communications related to the functionalities.
  • To provide You with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.

We may share Your personal information in the following situations:

  • With Service Providers: We share data with trusted third-party service providers (e.g., Stripe for payments, Cloud Providers for hosting) to facilitate the Service.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Do Not Sell or Share My Personal Information

We do not sell your personal information. We do not use the data inside Your Data Warehouse for any purpose other than providing the Service to You.

If you have questions regarding your data rights, please contact us at support@growthcues.com.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Specific to Warehouse Data: We generally retain a rolling buffer of event data (e.g., 60 days) to perform incremental processing. Upon termination of your Account, this data is deleted from our systems, though the original data remains in Your own Data Warehouse.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices (Finland) and in any other places where the parties involved in the processing are located.

If we transfer Personal Data outside the European Economic Area (EEA), such as to service providers in the United States (e.g., Stripe, Google), we ensure appropriate safeguards are in place, such as the EU-U.S. Data Privacy Framework or Standard Contractual Clauses (SCCs).

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

Your Rights under GDPR

If You are a resident of the European Economic Area (EEA), You have certain data protection rights. Arvoan aims to take reasonable steps to allow You to correct, amend, delete, or limit the use of Your Personal Data.

You have the following data protection rights:

  • The right to access, update or to delete the information We have on You.
  • The right of rectification. You have the right to have Your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of Your Personal Data.
  • The right of restriction. You have the right to request that We restrict the processing of Your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information We have on You in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You have the right to withdraw Your consent at any time where Arvoan relied on Your consent to process Your personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: