Last Updated: January 14, 2026
1. Introduction
THE SNOWBALL OF GROWTH S.R.L. ("Company", "we", "us", or "our") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (thesnowballofgrowth.com) and tell you about your privacy rights and how the law protects you.
We comply with the General Data Protection Regulation (GDPR) (EU) 2016/679 and relevant Romanian legislation regarding data protection.
2. Who We Are (Data Controller)
The entity responsible for your personal data (Data Controller) is:
Company Name: THE SNOWBALL OF GROWTH S.R.L.
Fiscal Registration Code (CUI): 53182345
European Unique Identifier (EUID): ROONRC.J2025100465009
Registered Office (Sediu Social): București Sectorul 3, Aleea EPRUBETEI, Nr. 25C, CAMERA 1, Etaj 8, Ap. 64.
Email Address: support@thesnowballofgrowth.com
3. The Data We Collect About You
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: First name, last name.
Contact Data: Email address, billing address (required for invoicing upon purchase).
Transaction Data: Details about payments to and from you and other details of products (courses) you have purchased from us. Note: We do not store your Credit Card information directly. Payments are processed via secure third-party gateways (Stripe/PayPal).
Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
Usage Data: Information about how you use our website, products, and services (e.g., course progress).
Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties.
4. How We Collect Your Data
Direct Interactions: You may give us your Identity and Contact Data by filling in forms on our landing pages (hosted on Systeme.io) or by corresponding with us by email.
Automated Technologies: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns via cookies and pixels (e.g., Facebook Pixel, Google Analytics/Tags).
5. How We Use Your Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Performance of Contract: To deliver the free mini-course, the paid "Digital Leverage Lab" course, or other services you requested.
Legitimate Interest: To run our business, prevent fraud, and improve our services via analytics.
Legal Obligation: To keep accounting records as required by Romanian Tax Law (ANAF).
Consent: To send you email marketing newsletters, affiliate offers (such as "Launch You" or "Launch Pad"), and promotional campaigns. You may withdraw consent at any time by clicking "Unsubscribe" at the bottom of our emails.
6. Disclosures of Your Data (Third Parties)
We do not sell your data. However, we share data with the following Data Processors who help us run our business. We ensure these parties respect the security of your data:
Systeme.io (IT Solutions): Our primary platform for hosting the website, courses, and sending emails.
Stripe / PayPal (Payment Processors): To securely process your payments.
Google & Meta (Facebook/Instagram): We use tracking pixels for advertising analytics and retargeting (showing you relevant ads based on your visits).
Romanian Authorities: We may disclose data to ANAF (National Agency for Fiscal Administration) if required by law for accounting purposes.
7. International Transfers
Some of our external third parties (like Systeme.io or Stripe) may be based outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring specific contracts approved by the European Commission are used (Standard Contractual Clauses) or that the providers are part of the EU-US Data Privacy Framework.
8. Data Retention
Marketing Data: We keep your email on our list until you unsubscribe.
Transaction Data: By Romanian law, we are required to keep financial/invoicing records for 10 years (archives).
9. Your Legal Rights
Under GDPR, you have rights including:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data ("Right to be forgotten").
Object to processing of your personal data.
Request restriction of processing.
Request transfer of your personal data.
Right to withdraw consent.
To exercise any of these rights, please email us at support@thesnowballofgrowth.com
10. Advertising and Retargeting
We use third-party advertising services (such as Facebook Ads and Google Ads) to display advertisements. These services may use cookies or pixels to track your activity on our site to show you ads relevant to your interests (Retargeting). By using our site and accepting our Cookie Policy, you consent to this tracking.
11. Complaints
You have the right to make a complaint at any time to the Romanian supervisory authority for data protection issues: ANSPDCP (Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal) - www.dataprotection.ro.
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