Last updated: 5 August 2026

1. Introduction

THE SNOWBALL OF GROWTH S.R.L. ("the Company", "we", "us", "our") respects your privacy and is committed to protecting your personal data. This policy explains how we look after your personal data when you visit www.thesnowballofgrowth.com, use our free training, our paid course, our community, and the software platform we provide, and it tells you about your privacy rights and how the law protects you.

We comply with the General Data Protection Regulation (EU) 2016/679 and applicable Romanian data protection legislation.

2. Who we are

The data controller responsible for your personal data is:

Company: THE SNOWBALL OF GROWTH S.R.L.

Fiscal registration code (CUI): 53182345

European unique identifier (EUID): ROONRC.J2025100465009

Registered office: București, Sectorul 3, Aleea Eprubetei, Nr. 25C, Camera 1, Etaj 8, Ap. 64, Romania

Email: support@thesnowballofgrowth.com

We have not appointed a Data Protection Officer, as we are not required to.

3. The data we collect

Identity data. First name, and last name where you give it.

Contact data. Email address, and billing address where required to issue an invoice.

Transaction data. Records of payments to and from you, and details of the subscriptions you have purchased. We never see or store your card details. Card payments are handled by Stripe.

Technical data. IP address, browser type and version, time zone and approximate location, operating system and device type.

Usage data. How you use the website, which lessons you open and complete, and how you use the platform and the community.

Content you create. Anything you post in the community, and anything you build or store inside the software platform, including your own contacts and lists.

Marketing data. Your preferences about receiving email from us, and whether you have unsubscribed.

We do not knowingly collect data from anyone under 18. Our services are not intended for children.

4. How we collect it

Directly from you, when you fill in a form to get the free training, create an account, buy a subscription, post in the community, or email us.

Automatically, as you use the site. We use CookieYes as our consent management platform, and cookies and pixels from Google Analytics, Google Ads and Meta. None of these fire until you have given consent through the banner. See the Cookie Policy.

From our platform provider, in the form of records of your account activity and lesson progress.

5. Why we use it, and on what legal basis

To provide what you signed up for. Creating and running your account, delivering the training and the course, granting community access, and providing the software platform. Legal basis: performance of a contract with you.

To run and improve the business. Providing support, preventing fraud, fixing account problems, and understanding in aggregate how people use the material so we can make it better. Legal basis: our legitimate interests, balanced against your rights.

To keep proper records. Issuing invoices and keeping accounts as Romanian tax law requires. Legal basis: legal obligation.

To send you email. The training sequence, the course emails, and marketing about what we do. Legal basis: your consent, given when you signed up. You can withdraw it at any time using the unsubscribe link at the bottom of every email, and withdrawing it does not affect anything we did before you withdrew it.

To advertise. Measuring our advertising and showing relevant ads to people who have visited the site. Legal basis: your consent, given through the cookie banner.

6. Who we share it with

We do not sell your personal data and we never will.

We share what is necessary with the following processors, each of whom is contractually bound to protect it:

Systeme.io. Our platform provider, for which we are an authorised reseller. They host the website, the courses, the community, the user dashboards and the email delivery.

Stripe. Payment processing and refunds, connected through Systeme.io.

Google. Google Analytics for site measurement, and Google Ads for advertising measurement and retargeting. Only after consent.

Meta. The Meta pixel, for advertising measurement and retargeting. Only after consent.

CookieYes. Recording and storing your cookie consent choices.

Our accountant, for invoicing and statutory accounts.

We may also disclose data where the law requires it, including to ANAF, the Romanian tax authority, and to courts or authorities responding to a lawful request.

7. Transfers outside the EEA

Some of these providers store or process data outside the European Economic Area. Where that happens we rely on the safeguards the law provides: Standard Contractual Clauses approved by the European Commission, or the provider's certification under the EU–US Data Privacy Framework. You can ask us for details of the safeguards applying to any particular transfer.

8. How long we keep it

Account and marketing data. For as long as your account is open, and for a reasonable period after you unsubscribe or close it. If you ask us to delete it, we delete it except where the law requires us to keep it.

Transaction and invoicing data. Ten years, as Romanian accounting law requires.

Community posts. For as long as the community runs. If you close your account you can ask us to remove or anonymise what you posted.

Data you store in the platform. For as long as your account is open. When it closes, it is deleted according to the platform provider's retention schedule, so export anything you need before you cancel.

9. Your rights

Under the GDPR you can ask us to:

• give you a copy of the personal data we hold about you

• correct anything that is wrong

• delete your data, where there is no legal reason for us to keep it

• restrict what we do with it, while a question about it is resolved

• send your data to you or another provider in a portable format

• stop processing it where we rely on legitimate interests

• stop sending you marketing, at any time and without giving a reason

You can also withdraw consent at any time, for email or for cookies, without affecting anything done before you withdrew it.

Write to support@thesnowballofgrowth.com. We will respond within one month. There is no charge, unless a request is clearly unfounded or excessive.

10. Security

We rely on the security measures of our platform and payment providers, both of whom hold recognised security certifications, together with access controls on our own accounts. No system is completely secure. If a breach occurs that is likely to put your rights at risk, we will tell you and the supervisory authority as the law requires.

11. Your own use of the platform

If you use the software platform to collect and store contact details of your own leads and customers, you are the controller of that data and we act as a processor on your behalf. Your obligations to those people are yours, including giving them a privacy notice and a lawful basis for contacting them. Ask us for a data processing agreement covering this relationship.

12. Complaints

If you are unhappy with how we have handled your data, please tell us first at support@thesnowballofgrowth.com so we can try to put it right.

You also have the right to complain to the Romanian supervisory authority:

ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal) B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, București www.dataprotection.ro

If you live in another EU country you may complain to your own national authority instead.

13. Changes

We may update this policy. When we do, we change the date at the top. If a change materially affects your rights, we will tell you by email.