PRIVACY POLICY

Last Updated: September, 2026

Click Growths ("Click Growths," "we," "us," or "our") respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how we collect, use, store, disclose, and otherwise process personal information when you:

• visit clickgrowths.com;
• access or use app.clickgrowths.com;
• create or use an account;
• purchase or use our products or services;
• submit a form or book an appointment;
• communicate with us by email, telephone, SMS, chat, or other methods;
• interact with our marketing;
• use our CRM, automation, communication, artificial intelligence, or related Platform features; or
• otherwise interact with Click Growths.

This Privacy Policy should be read together with our Terms of Service available at:

clickgrowths.com/terms-of-service

If you do not agree with this Privacy Policy, you should not use our websites, Platform, or Services.

1. WHO WE ARE

Click Growths provides marketing technology, CRM functionality, automation tools, communication tools, artificial intelligence features, marketing services, and related business services.

For purposes of this Privacy Policy:

Website means clickgrowths.com and webpages operated by Click Growths.

Platform means app.clickgrowths.com and related CRM, automation, communication, software, AI, integration, and account functionality made available by Click Growths.

Services means the Website, Platform, and other products or services provided by Click Growths.

Personal Information or Personal Data means information that identifies, relates to, describes, can reasonably be linked to, or can reasonably identify an individual, as defined under applicable privacy law.

Customer means a business or person that obtains Services from Click Growths.

End User means a lead, prospect, customer, employee, contractor, website visitor, contact, or other individual whose information a Customer processes through the Platform.

2. OUR ROLE WHEN PROCESSING PERSONAL INFORMATION

Our legal role depends on whose information we are processing and why.

A. Information Click Growths Collects for Its Own Purposes

When you:

• visit our Website;
• create a Click Growths account;
• contact Click Growths;
• purchase Services from us;
• request support;
• subscribe to our marketing;
• interact with our advertisements; or
• otherwise deal directly with Click Growths,

Click Growths generally determines why and how that Personal Information is processed.

Depending on applicable law, Click Growths may therefore act as the data controller, business, or data fiduciary for this information.

B. Information Our Customers Process Through the Platform

Our Customers may use the Platform to collect, upload, store, manage, communicate with, automate, or otherwise process information belonging to their own customers, leads, prospects, employees, website visitors, or other individuals.

Examples include:

• CRM contact records;
• leads generated through forms or advertising;
• appointment information;
• email addresses;
• telephone numbers;
• SMS communications;
• email communications;
• call information;
• form submissions;
• survey responses;
• pipeline information;
• notes;
• customer records;
• transaction information; and
• other data entered into the Platform by a Customer.

For this information, the Customer generally determines why and how the information is processed.

Click Growths generally processes such information on behalf of the Customer.

Depending on applicable law, the Customer may therefore act as the controller, business, or data fiduciary, while Click Growths may act as its processor, service provider, or data processor.

Our technology and infrastructure providers may act as further processors or subprocessors.

If your information was collected by one of our Customers rather than directly by Click Growths, that Customer's privacy policy will generally govern how your information is used.

3. INFORMATION WE COLLECT

The information we collect depends on how you interact with Click Growths and which Services you use.

We may collect the following categories of information.

A. Identity and Contact Information

This may include:

• name;
• business name;
• job title;
• email address;
• telephone number;
• mailing address;
• billing address; and
• other contact information.

B. Account Information

When you create or use an Account, we may process:

• username;
• account identifier;
• login information;
• authentication information;
• account permissions;
• user roles;
• profile information;
• preferences;
• subscription information; and
• security information.

Passwords may be stored using security measures designed to prevent them from being readable in ordinary form.

4. BUSINESS AND COMMERCIAL INFORMATION

We may collect information regarding your business and your relationship with Click Growths, such as:

• business name;
• industry;
• business website;
• products or services;
• marketing requirements;
• subscription plan;
• Services purchased;
• purchase history;
• invoices;
• account balances;
• service usage;
• customer support history; and
• other information relating to our commercial relationship.

5. PAYMENT AND BILLING INFORMATION

When you purchase Services, payment information may be collected or processed by us or our payment processing providers.

This may include:

• billing name;
• billing address;
• transaction information;
• payment status;
• payment method type;
• transaction identifiers; and
• limited payment card information provided to us by the payment processor.

We may not directly receive or store complete payment card numbers where payments are handled by a third-party payment processor.

Payment processors process payment information under their own terms and privacy practices.

6. COMMUNICATION INFORMATION

If you communicate with Click Growths or use communication functionality through the Platform, information may include:

• email messages;
• SMS or MMS messages;
• RCS messages;
• chat messages;
• telephone numbers;
• call information;
• voicemail;
• communication timestamps;
• sender and recipient information;
• delivery information;
• opt-in records;
• opt-out records;
• support conversations;
• appointment conversations; and
• other communication content or metadata.

Where permitted by applicable law and where the relevant functionality is enabled, calls or conversations may also be recorded, transcribed, summarized, or analyzed.

Appropriate notice or consent should be obtained where legally required.

7. INFORMATION COLLECTED AUTOMATICALLY

When you access our Website or Platform, we and our technology providers may automatically collect certain technical and usage information.

This may include:

• IP address;
• browser type;
• operating system;
• device type;
• device identifiers;
• referring URL;
• pages viewed;
• links clicked;
• session information;
• login activity;
• approximate geographic location derived from IP address;
• timestamps;
• website interactions;
• Platform activity;
• error logs;
• security logs;
• communication logs; and
• other diagnostic or usage information.

We may collect this information using cookies, pixels, tags, scripts, logs, local storage, software development kits, and similar technologies.

8. INFORMATION FROM FORMS, CALENDARS AND WEBSITES

Information may be collected when you or an End User:

• completes a contact form;
• submits a lead form;
• completes a survey;
• books an appointment;
• starts a web chat;
• registers for an event;
• purchases a product or service;
• requests information; or
• otherwise provides information through a page powered by our Services.

The information collected depends on the fields configured by Click Growths or the applicable Customer.

9. INFORMATION FROM THIRD PARTIES

We may receive information from third parties where permitted by law.

These may include:

• advertising platforms;
• social media platforms;
• analytics providers;
• lead generation providers;
• integration partners;
• public sources;
• data providers;
• payment processors;
• telecommunications providers;
• referral partners;
• Customers;
• software integrations; and
• other service providers.

If you connect a third-party account or application to the Platform, information may be exchanged between the Platform and that service according to your configuration and the applicable provider's privacy practices.

10. CUSTOMER-CONTROLLED DATA

Customers may upload, import, synchronize, collect, or generate Personal Information through the Platform.

This may include information regarding:

• leads;
• prospects;
• customers;
• employees;
• contractors;
• appointments;
• transactions;
• sales opportunities;
• marketing activities;
• customer conversations;
• form submissions;
• communications;
• website visitors; and
• other business contacts.

Customers are responsible for ensuring that they have a lawful basis, permission, authorization, or consent necessary to collect and use this information.

Click Growths processes Customer-controlled Personal Information primarily to provide the Services requested by the Customer.

11. HOW WE USE PERSONAL INFORMATION

Depending on the circumstances, we may use Personal Information to:

Provide the Services

Including to:

• operate the Website and Platform;
• create and manage Accounts;
• provide CRM functionality;
• provide automation functionality;
• provide forms, surveys, calendars, websites, and funnels;
• provide communications functionality;
• process transactions;
• provide integrations; and
• deliver requested products and Services.

Manage Customer Relationships

Including to:

• process subscriptions;
• manage billing;
• maintain records;
• administer Accounts;
• communicate about Services;
• respond to questions;
• provide onboarding;
• provide customer support; and
• resolve technical issues.

Operate and Improve Our Services

Including to:

• understand how our Website and Platform are used;
• diagnose errors;
• analyze performance;
• improve functionality;
• develop features;
• conduct testing;
• generate statistics; and
• improve user experience.

Protect the Platform and Our Users

Including to:

• authenticate users;
• detect suspicious activity;
• prevent fraud;
• investigate abuse;
• enforce our Terms;
• secure Accounts;
• monitor system performance; and
• prevent unauthorized access.

Communicate With You

Including to send:

• account notifications;
• billing communications;
• security alerts;
• service notifications;
• appointment information;
• requested communications;
• customer support responses;
• policy updates; and
• other administrative communications.

Marketing and Advertising

Where permitted by applicable law, we may use information to:

• send marketing communications;
• advertise Click Growths Services;
• measure advertising performance;
• understand campaign effectiveness;
• build audiences;
• personalize marketing;
• understand visitor interests; and
• improve our marketing activities.

You may opt out of marketing communications as described below.

Legal and Compliance Purposes

We may process Personal Information to:

• comply with applicable law;
• respond to lawful requests;
• maintain accounting and tax records;
• investigate disputes;
• protect legal rights;
• prevent illegal activity;
• establish or defend legal claims; and
• comply with contractual or regulatory obligations.

12. LEGAL BASES FOR PROCESSING

Where applicable privacy law requires a legal basis for processing, we may rely on one or more of the following:

Contract

Processing may be necessary to provide Services you requested or to perform our agreement with you.

Consent

We may process Personal Information where you have provided valid consent.

You may withdraw consent where applicable, subject to legal and contractual limitations.

Legitimate Interests

We may process Personal Information where necessary for legitimate business interests, such as:

• operating our business;
• providing support;
• preventing fraud;
• improving Services;
• protecting security;
• conducting appropriate marketing; and
• maintaining customer relationships,

provided those interests are not overridden by rights that apply under applicable law.

Legal Obligation

We may process information where required to comply with law or a binding legal requirement.

Other Lawful Grounds

We may rely on another legal basis permitted by applicable privacy legislation.

13. ARTIFICIAL INTELLIGENCE FEATURES

Some Platform features may use artificial intelligence, machine learning, voice AI, conversational AI, generative AI, or similar technologies.

When you use these features, information processed may include:

• prompts;
• instructions;
• conversation content;
• contact information;
• recordings;
• transcripts;
• CRM information;
• documents;
• generated responses; and
• related technical information.

This information may be processed by specialized technology providers solely as necessary to provide the relevant functionality, subject to their applicable contractual and privacy safeguards.

We do not intentionally use Customer-controlled Personal Information to train publicly available general-purpose AI models for our own independent purposes.

Customers should not submit sensitive or regulated information into AI features unless they have confirmed that doing so is lawful and appropriate.

Customers are responsible for obtaining any legally required consent or providing any legally required notice before using AI systems to process information about End Users.

14. COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies and similar technologies on our Website and Platform.

These technologies may help us:

• keep users logged in;
• remember preferences;
• maintain security;
• prevent fraud;
• understand Website traffic;
• measure Platform usage;
• diagnose technical problems;
• understand marketing performance;
• provide Website functionality;
• personalize content; and
• support advertising activities.

Cookies may generally fall into categories such as:

Strictly Necessary Cookies

Required for security, authentication, account access, session management, and core Website functionality.

Functional Cookies

Used to remember preferences and provide enhanced functionality.

Analytics and Performance Cookies

Used to understand Website traffic, Platform performance, and user interactions.

Advertising and Marketing Cookies

Where used, these technologies may help measure advertising campaigns, understand conversions, build advertising audiences, or provide more relevant advertising.

Depending on our technology configuration, these services may involve providers such as analytics, advertising, CRM, website, or social media platforms.

You may be able to control cookies through your browser settings or a cookie consent tool where one is provided.

Blocking certain cookies may affect Website or Platform functionality.

15. ADVERTISING, "SALE," SHARING AND TARGETED ADVERTISING

Click Growths does not sell Personal Information to third parties for money.

However, some privacy laws use broad definitions of terms such as "sale," "sharing," or "targeted advertising."

Under those laws, use of certain advertising pixels, cookies, audience technologies, or marketing partners may potentially qualify as sharing, sale, or targeted advertising even when no money is paid in exchange for Personal Information.

Where applicable law gives you a right to opt out of these activities, you may exercise that right using available cookie/privacy controls or by contacting us at:

support@clickgrowths.com

We will process valid requests in accordance with applicable law.

16. SMS AND MOBILE INFORMATION

We take mobile messaging privacy seriously.

We do not provide your mobile telephone number or SMS marketing consent to third parties or affiliates for their independent marketing or promotional purposes.

SMS or text messaging opt-in information and consent records may be disclosed only where reasonably necessary to providers involved in delivering or supporting the messaging service, such as telecommunications carriers, messaging aggregators, platform providers, or other service providers, or where required by law.

Mobile information will not be transferred to third parties for their own marketing purposes merely because you consented to receive text messages from Click Growths or one of our Customers.

You may opt out of applicable SMS marketing at any time using the opt-out instructions included in the message, such as replying STOP, where supported.

17. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose Personal Information to the following categories of recipients where necessary and lawful.

Service Providers and Subprocessors

We rely on providers that may assist with:

• hosting;
• cloud infrastructure;
• CRM infrastructure;
• communications;
• email delivery;
• SMS and telephone services;
• payment processing;
• analytics;
• artificial intelligence;
• workflow automation;
• identity or fraud prevention;
• website functionality;
• customer support;
• security; and
• related technology.

These providers may process information only as necessary for the services they provide to us, subject to applicable contracts and legal requirements.

Not every provider processes information relating to every user.

Integrated Third-Party Services

If you or a Customer connects an external application to the Platform, information may be exchanged with that provider as necessary to operate the integration.

Professional Advisers

We may share information with accountants, lawyers, consultants, insurers, auditors, or similar professional advisers where reasonably necessary.

Legal and Regulatory Authorities

We may disclose information where reasonably necessary to:

• comply with applicable law;
• respond to court orders or lawful government requests;
• investigate illegal conduct;
• enforce agreements;
• protect our rights;
• protect users; or
• prevent harm.

Business Transactions

Information may be transferred as part of or in preparation for a:

• merger;
• acquisition;
• financing;
• restructuring;
• sale of assets;
• transfer of business;
• insolvency proceeding; or
• similar corporate transaction.

At Your Direction

We may disclose Personal Information where you instruct or authorize us to do so.

18. THIRD-PARTY PLATFORM PROVIDERS AND SUBPROCESSORS

Click Growths uses third-party technology and infrastructure providers to deliver portions of the Platform.

These providers may operate infrastructure or process information in countries other than your own.

Depending on the Services and features used, providers may support:

• cloud storage;
• CRM functionality;
• SMS and telecommunications;
• email delivery;
• artificial intelligence;
• payment processing;
• integrations;
• analytics;
• workflow automation; and
• customer support.

A specific provider may change from time to time as Services evolve.

Where required by applicable law or contract, Click Growths will use appropriate agreements and safeguards when engaging processors or subprocessors.

Customers that require additional information about relevant subprocessors may contact:

support@clickgrowths.com

19. INTERNATIONAL DATA TRANSFERS

Click Growths is based in Mohali, Punjab, India, but the Services rely on technology and service providers operating internationally.

As a result, Personal Information may be processed or stored in:

• India;
• the United States; and
• other countries where our service providers or their subprocessors operate.

Privacy and data protection laws in those countries may differ from those in your country.

Where required by applicable law, we use or rely on appropriate legal mechanisms intended to protect Personal Information transferred internationally.

These may include:

• contractual data protection provisions;
• Standard Contractual Clauses where applicable;
• approved transfer frameworks;
• adequacy mechanisms;
• processor agreements; or
• other lawful transfer safeguards.

20. DATA RETENTION

We retain Personal Information only for as long as reasonably necessary for the purposes for which it was collected.

Retention periods may depend on:

• the nature of the information;
• our relationship with you;
• the duration of your Account;
• Customer instructions;
• security requirements;
• contractual obligations;
• dispute requirements;
• legal requirements;
• tax or accounting obligations; and
• legitimate business requirements.

We may retain information longer where necessary in connection with:

• legal claims;
• disputes;
• fraud prevention;
• investigations;
• regulatory requirements; or
• other lawful purposes.

Where appropriate, Personal Information may be deleted, anonymized, or aggregated after the applicable retention period.

Information that has been irreversibly anonymized and can no longer identify an individual may be retained for analytics, statistical, or business purposes.

21. ACCOUNT CANCELLATION AND CUSTOMER DATA

Customers should export any Customer Data they require before terminating their Account.

After cancellation or termination, Customer Data may remain within systems, backups, or underlying service providers for a limited period.

We do not guarantee indefinite access to Customer Data after termination.

Information may subsequently be deleted or anonymized according to our retention practices, Customer instructions, provider policies, contractual requirements, and applicable law.

Some information may continue to be retained where legally required or reasonably necessary for legitimate purposes such as accounting, fraud prevention, security, disputes, or legal compliance.

22. INFORMATION SECURITY

We use reasonable administrative, organizational, and technical measures designed to protect Personal Information against:

• unauthorized access;
• accidental loss;
• improper use;
• unauthorized alteration;
• unauthorized disclosure;
• destruction; and
• other security risks.

Our technology providers are also expected to maintain appropriate security protections for information they process on our behalf.

However, no website, internet transmission, cloud service, telecommunications network, storage system, or security method can be guaranteed to be completely secure.

You are responsible for:

• keeping your Account credentials confidential;
• using strong passwords;
• using multi-factor authentication where available;
• controlling employee access;
• securing devices;
• protecting API credentials; and
• promptly informing us about suspected unauthorized access.

If you believe your Account or Personal Information has been compromised, contact us at:

support@clickgrowths.com

23. DATA BREACHES AND SECURITY INCIDENTS

If we become aware of a security incident affecting Personal Information, we will investigate and take measures we consider appropriate based on the nature and circumstances of the incident.

Where required by applicable law, we will provide notice to affected parties, Customers, regulators, or other authorities within legally required timeframes.

Where Click Growths processes Personal Information on behalf of a Customer, we may notify the relevant Customer so that the Customer can satisfy its own legal obligations.

24. CHILDREN'S PRIVACY

The Services are intended primarily for businesses and are not directed to children.

We do not knowingly collect Personal Information directly from children under 16 for our own commercial purposes.

If we learn that we have collected Personal Information from a child contrary to applicable law, we may take reasonable steps to delete it.

If you believe a child has provided Personal Information to Click Growths improperly, contact:

support@clickgrowths.com

Customers using the Platform are responsible for ensuring that their own collection of children's information complies with applicable law.

25. YOUR PRIVACY RIGHTS

Depending on where you live and applicable law, you may have rights relating to your Personal Information.

These may include the right to:

• know whether we process your Personal Information;
• request access to Personal Information;
• obtain a copy of Personal Information;
• correct inaccurate information;
• request deletion;
• request restriction of processing;
• object to certain processing;
• withdraw consent;
• request portability;
• opt out of certain marketing;
• opt out of qualifying targeted advertising;
• opt out of qualifying sales or sharing;
• object to certain automated decision-making;
• appeal certain privacy-request decisions; and
• lodge a complaint with an applicable regulator.

These rights are not absolute and may be limited by applicable law.

We may need to verify your identity before completing a request.

We will not unlawfully discriminate against you for exercising an applicable privacy right.

26. PRIVACY RIGHTS FOR PEOPLE IN INDIA

Where the Digital Personal Data Protection Act, 2023, the Digital Personal Data Protection Rules, 2025, or other applicable Indian privacy requirements apply, individuals may have rights and remedies provided by those laws as and when the relevant provisions become effective.

Where applicable, this may include rights relating to:

• information about processing;
• correction;
• completion;
• updating;
• erasure;
• grievance redressal; and
• other rights provided under applicable Indian data protection law.

Requests relating to Personal Information for which Click Growths determines the purpose and means of processing may be sent to:

support@clickgrowths.com

Where Click Growths processes information only on behalf of one of our Customers, requests may need to be handled by that Customer.

27. EUROPEAN, UK AND SWISS PRIVACY RIGHTS

If applicable European, United Kingdom, or Swiss privacy legislation applies to your information, you may have rights including:

• access;
• correction;
• deletion;
• restriction;
• objection;
• portability;
• withdrawal of consent; and
• the right to complain to an applicable supervisory authority.

Where we rely on consent, withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Where we rely on legitimate interests, you may have the right to object in circumstances provided by applicable law.

Where required, Personal Information transferred internationally will be handled using applicable transfer safeguards.

28. UNITED STATES PRIVACY RIGHTS

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws.

Depending on the law and circumstances, these may include rights to:

• confirm whether Personal Information is processed;
• access Personal Information;
• correct Personal Information;
• delete Personal Information;
• obtain a portable copy;
• opt out of qualifying sales;
• opt out of qualifying sharing;
• opt out of targeted advertising;
• opt out of certain profiling;
• use an authorized agent; and
• appeal a denied privacy request.

California Residents

California law may classify certain disclosures involving advertising technology as a "sale" or "sharing" even where Click Growths does not receive money for Personal Information.

Click Growths does not sell Personal Information for money.

If our use of advertising or tracking technologies qualifies as a sale or sharing under applicable California law, eligible individuals may request to opt out.

Sensitive Personal Information

Where we process information legally classified as sensitive Personal Information, we will use it only as authorized, required, or otherwise permitted by applicable law.

Non-Discrimination

We will not unlawfully discriminate against an individual for exercising applicable privacy rights.

29. MARKETING COMMUNICATIONS

You may opt out of marketing emails by using the unsubscribe link contained in an applicable email.

You may opt out of applicable SMS marketing using the instructions included with the communication, such as replying STOP, where supported.

You may also contact:

support@clickgrowths.com

Opting out of marketing does not necessarily prevent us from sending non-marketing communications such as:

• billing notices;
• security alerts;
• account notices;
• transactional messages;
• service updates;
• legal notices; or
• support communications.

30. CUSTOMER END-USER PRIVACY REQUESTS

This section is important if your information appears inside the Platform because you are a lead, customer, employee, prospect, or other contact of one of our Customers.

In those circumstances, Click Growths may be processing your Personal Information only on behalf of that Customer.

The Customer generally controls:

• why your information was collected;
• which information was collected;
• how your information is used;
• how long it is retained;
• which communications are sent; and
• whether your information should be corrected or deleted.

You should therefore normally direct your privacy request to the business that originally collected your Personal Information.

If we receive a request relating to Customer-controlled information, we may:

• identify the applicable Customer;
• refer the request to that Customer;
• notify the Customer; or
• assist the Customer with fulfilling the request where appropriate.

We will not independently change or delete Customer-controlled information where doing so would improperly override the Customer's lawful instructions.

31. THIRD-PARTY WEBSITES AND SERVICES

Our Website or Platform may link to websites, applications, payment processors, social networks, advertising platforms, or other services operated by third parties.

We are not responsible for the privacy, security, content, or practices of third-party services that operate independently from Click Growths.

You should review their applicable privacy policies before providing Personal Information.

32. DO NOT TRACK AND GLOBAL PRIVACY SIGNALS

Some browsers offer a "Do Not Track" setting.

Because there is not a universally adopted standard for interpreting traditional Do Not Track signals, our systems may not respond to all such signals.

Where applicable law requires recognition of legally valid browser-based opt-out preference signals, such as Global Privacy Control (GPC), we may process such signals in accordance with applicable law and the capabilities of our Website and consent-management technologies.

33. HOW TO MAKE A PRIVACY REQUEST

To exercise an applicable privacy right or ask a privacy-related question, contact:

support@clickgrowths.com

Please include sufficient information for us to understand and process your request.

We may request additional information where reasonably necessary to:

• verify your identity;
• determine which Account or Customer is involved;
• protect against fraudulent requests; or
• determine whether the requested right applies.

Authorized agents may submit requests where permitted by applicable law, subject to reasonable verification.

34. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• changes to our Services;
• new Platform functionality;
• new service providers;
• changes in our business;
• changes in technology;
• changes in legal requirements; or
• changes in our privacy practices.

When we update the Privacy Policy, we will revise the Last Updated date at the top of this page.

Where required by applicable law, we may provide additional notice of material changes.

35. CONTACT US

For questions regarding this Privacy Policy, Personal Information, privacy rights, or our privacy practices, contact:

Click Growths

Website: clickgrowths.com

Platform: app.clickgrowths.com

Email: support@clickgrowths.com

Location: Mohali, Punjab, India

Privacy requests may be submitted to:

support@clickgrowths.com