10X Growth - Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors. and

service users.

1.2 This policy applies where we are acting as a data controller with respect to

the personal data of our website visitors and service users; in other words,

where we determine the purposes and means of the processing of that

personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly

necessary for the provision of our website and services, we will ask you to

consent to our use of cookies when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to 10xGrowth. For more

information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal

(https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

3.2 We may process data about your use of our website and services ("usage

data"). The usage data may include your geographical location,

browser type and version, referral source, length of visit,

page views and website navigation paths, as well as information about the

timing, frequency and pattern of your service use. The source of the usage

data is Google Analytics. This usage data may be processed for the

purposes of analysing the use of the website and services. The legal basis for

this processing is consent OR our legitimate interests, namely monitoring and

improving our website and services.

3.3 We may process your information that you leave, email + email adress. We will

use this information to contact you once we continue with the actual shipping of

products. The legal basis for this is consent.

3.4 We may process information contained in any enquiry you submit to us

regarding goods and/or services ("enquiry data"). The enquiry data may be

processed for the purposes of offering, marketing and selling relevant goods

and/or services to you. The legal basis for this processing is consent.

3.5 We may process information that you provide to us for the purpose of

subscribing to our email notifications and/or newsletters ("notification

data"). The notification data may be processed for the purposes of sending

you the relevant notifications and/or newsletters. The legal basis for this

processing is consent OR the performance of a contract between you and us

and/or taking steps, at your request, to enter into such a contract.

3.6 In addition to the specific purposes for which we may process your personal

data set out in this Section 3, we may also process any of your personal data

where such processing is necessary for compliance with a legal obligation to

which we are subject, or in order to protect your vital interests or the vital

interests of another natural person.

3.7 Please do not supply any other person's personal data to us, unless we

prompt you to do so.

4. Providing your personal data to others

4.1 We do not disclose your personal information to external parties.The data is

only used by authorized employees of 10xGrowth.

4.2 Financial transactions relating to our website and services may be handled by

our payment services providers (Paypal & Shopify). We will share transaction

data with our payment services providers only to the extent necessary for the

purposes of processing your payments, refunding such payments and dealing

with complaints and queries relating to such payments and refunds. You can

find information about the payment services providers' privacy policies and

practices at https://www.shopify.com/legal/privacy,

https://www.paypal.com/en/webapps/mpp/ua/privacy-full .

5. International transfers of your personal data

5.1 The hosting facilities for our website are situated in Netherlands

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are

designed to help ensure that we comply with our legal obligations in relation

to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept

for longer than is necessary for that purpose or those purposes, with am maximum

of three months.

6.3 We will retain your personal data as follows:

Newsletter subscriptions:

(a) Surname, email address, Unsubscribe.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your

personal data where such retention is necessary for compliance with a legal

obligation to which we are subject, or in order to protect your vital interests

or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on

our website.

7.2 You should check this page occasionally to ensure you are happy with any

changes to this policy.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data

protection law. Some of the rights are complex, and not all of the details have

been included in our summaries. Accordingly, you should read the relevant

laws and guidance from the regulatory authorities for a full explanation of

these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your

personal data and, where we do, access to the personal data, together with

certain additional information. That additional information includes details of

the purposes of the processing, the categories of personal data concerned

and the recipients of the personal data. Providing the rights and freedoms of

others are not affected, we will supply to you a copy of your personal data.

The first copy will be provided free of charge, but additional copies may be

subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified

and, taking into account the purposes of the processing, to have any

incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal

data without undue delay. Those circumstances include:[the personal data

are no longer necessary in relation to the purposes for which they were

collected or otherwise processed; you withdraw consent to consent-based

processing; you object to the processing under certain rules of applicable

data protection law; the processing is for direct marketing purposes; and the

personal data have been unlawfully processed. However, there are exclusions

of the right to erasure. The general exclusions include where processing is

necessary: for exercising the right of freedom of expression and information;

for compliance with a legal obligation; or for the establishment, exercise or

defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your

personal data. Those circumstances are: you contest the accuracy of the

personal data; processing is unlawful but you oppose erasure; we no longer

need the personal data for the purposes of our processing, but you require

personal data for the establishment, exercise or defence of legal claims; and

you have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to store

your personal data. However, we will only otherwise process it: with your

consent; for the establishment, exercise or defence of legal claims; for the

protection of the rights of another natural or legal person; or for reasons of

important public interest.

8.7 You have the right to object to our processing of your personal data on

grounds relating to your particular situation, but only to the extent that the

legal basis for the processing is that the processing is necessary for: the

performance of a task carried out in the public interest or in the exercise of

any official authority vested in us; or the purposes of the legitimate interests

pursued by us or by a third party. If you make such an objection, we will

cease to process the personal information unless we can demonstrate

compelling legitimate grounds for the processing which override your

interests, rights and freedoms, or the processing is for the establishment,

exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct

marketing purposes (including profiling for direct marketing purposes). If you

make such an objection, we will cease to process your personal data for this

purpose.

8.9 You have the right to object to our processing of your personal data for

scientific or historical research purposes or statistical purposes on grounds

relating to your particular situation, unless the processing is necessary for the

performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to

which you are party or in order to take steps at your request prior to

entering into a contract,

and such processing is carried out by automated means, you have the right

to receive your personal data from us in a structured, commonly used and

machine-readable format. However, this right does not apply where it would

adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes

data protection laws, you have a legal right to lodge a complaint with a

supervisory authority responsible for data protection. You may do so in the

EU member state of your habitual residence, your place of work or the place

of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal

information is consent, you have the right to withdraw that consent at any

time. Withdrawal will not affect the lawfulness of processing before the

withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by

written notice to us OR by contacting us via admin@10xgrowth.nl

in addition to the other methods specified in this Section 8].

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that

is sent by a web server to a web browser and is stored by the browser. The

identifier is then sent back to the server each time the browser requests a

page from the server.

9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent

cookie will be stored by a web browser and will remain valid until its set

expiry date, unless deleted by the user before the expiry date; a session

cookie, on the other hand, will expire at the end of the user session, when the

web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a

user, but personal information that we store about you may be linked to the

information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our

website and as you navigate our website.

(b) analysis - we use cookies to help us to analyse the use and

performance of our website and services

the use of cookies more generally.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies maybe stored on your

computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics

gathers information about website use by means of cookies. The information

gathered relating to our website is used to create reports about the use of our

website. Google's privacy policy is available at:

https://www.google.com/policies/privacy/.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies.

The methods for doing so vary from browser to browser, and from version to

version. You can however obtain up-to-date information about blocking and

deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookieswebsite-

preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-

delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-andprivacy

(Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many

websites.

12.3 If you block cookies, you will not be able to use all the features on our

website.

13. Our details

13.1 This website is owned and operated by 10xGrowth BV

13.2 We are registered in Netherlands under registration number 89955161and

our registered office is at Westmadeweg 129, 2553EK Den Haag

13.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form: www.10xgrowth.nl/contact

14. Data protection officer

14.1 Our data protection officer's contact details are: Misha de Sterke

admin@10xgrowth.nl