Privacy Policy

Last Updated: 10/01/2025

At Davinci Growth, LLC ("Company," "we," "our," or "us"), we value your privacy and are committed to protecting personal information. This Privacy Policy explains how we collect, use, and safeguard information when you visit our websites, engage with our ads or emails, apply for a role, or use our services.

1. Information We Collect

We may collect the following types of information:

• Personal Information: name, email address, (optional) phone number, company, role, and limited billing details when you inquire, sign up, or become a client.

• Business/Project Information: brand details, campaign briefs, product data, creative assets, and related materials you provide so we can deliver marketing and advertising services.

• Technical Data: IP address, device/browser type, operating system, referring/exit pages, pages viewed, clicks/scrolls, session timing, approximate location, and similar analytics. Collected via cookies, pixels, tags, SDKs, and local storage.

• Communications: messages, meetings, recordings/notes (where applicable), testimonials, and support interactions.

• Payment Information: Payments are processed by PCI‑compliant third‑party processors. We do not store full card numbers on our servers. For our trial ad creatives offer, we securely store payment credentials as tokens with our payment processor so we can seamlessly bill if you enter a retainer services agreement per your order terms.

We may also receive information about you from third parties such as analytics/advertising platforms, CRM and email tools, scheduling/forms, payment processors, data enrichment providers, storefronts, and social platforms. We may combine information from these sources to improve accuracy and service.

(EEA/UK/Switzerland lawful bases, where applicable: contract, legitimate interests, consent where required—e.g., certain cookies/marketing—and legal obligation.)

2. How We Use Your Information

We use information to:

• Provide & improve our websites and services (deliver campaigns, manage accounts, measure performance, QA/test features).

• Process orders and payments, issue invoices/receipts, and administer client accounts.

• Communicate about projects, deliverables, updates, support, and transactional notices.

• Personalize & advertise where permitted (audience creation, retargeting, frequency capping, and performance measurement).

• Run analytics & research (attribution, funnel analysis, experimentation) to enhance user experience and service quality.

• Ensure security & prevent fraud, comply with legal, tax, and contractual obligations, and exercise/defend legal claims.

• Recruiting & HR (evaluate candidates and onboarding, where applicable).

3. How We Protect Your Information

We employ reasonable administrative, technical, and physical safeguards designed to protect personal data (e.g., encryption in transit, access controls, least‑privilege practices, and PCI‑compliant payment processing via third‑party providers). However, no method of transmission or storage is 100% secure.

4. Sharing of Information

We do not sell personal information for money. We may share information with:

• Service providers/processors that support our operations (hosting, analytics, email/SMS, CRM, project/file tools, payments, scheduling/forms, advertising/measurement). These parties are contractually limited to using data solely to provide services to us.

• Advertising/analytics partners to measure campaigns and improve relevance where allowed by law/consent.

• Clients (e.g., campaign performance and leads generated for the client, or when we process data on a client’s behalf to deliver services under contract).

• Professional advisors (legal, accounting, audit) and as part of business transfers (e.g., merger, acquisition, asset sale).

• Legal/safety needs to comply with law, enforce agreements, or protect rights, safety, and property.

When we use advertising platforms, we configure them to avoid disclosures that would constitute a "sale" under applicable state laws (e.g., using service‑provider modes or aggregated reporting where available).

5. Additional Program Notes (Davinci Growth–Specific)

Trial Batch Ad Creatives → Creative Ascension Retainer: We store payment credentials as processor tokens (not card numbers) to streamline billing if you proceed to a retainer per your order agreement. We do not use payment information for any other purpose.

6. Acting as a Service Provider to Clients

For certain services, we process personal data on behalf of our clients and only under their instructions (client is the controller/business; Davinci Growth is the processor/service provider). Upon termination or at a client’s request, we delete or return personal data as required by contract and law.

7. Cookies & Tracking Technologies

We use cookies and similar technologies for:

• Essential functionality & security

• Analytics & performance (e.g., Google Analytics)

• Advertising & measurement (e.g., Meta pixel, Google Ads, LinkedIn, TikTok)

You can manage cookies via your browser and, where implemented, our on‑site preferences banner. Disabling certain cookies may impact site functionality.

8. Your Rights & Choices

Depending on your location, you may have rights to access/know, correct, delete, restrict/object (EEA/UK), portability, and withdraw consent (where processing is based on consent). You can also:

• Opt out of marketing emails via unsubscribe links.

• Manage ad preferences in your browser/platform settings and via industry tools (e.g., NAI/DAA) where available.

To exercise rights or submit a privacy request, email privacy@davincigrowth.com. We will verify requests consistent with applicable law and will not discriminate for exercising rights.

9. Third‑Party Links

Our websites may link to third‑party sites/platforms. Their practices are governed by their own policies. Review those policies before providing personal information.

10. International Transfers & Retention

We may transfer, store, and process information in countries other than where it was collected (including the United States). Where required, we use safeguards such as Standard Contractual Clauses for EEA/UK/Switzerland transfers. We retain information for as long as necessary for the purposes described above and to meet legal/accounting/reporting obligations, then delete, de‑identify, or aggregate it where feasible.

11. Children’s Privacy

Our services are not directed to children under 13 (or the minimum age required by law in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us to request deletion.

12. Changes to This Privacy Policy

We may update this Policy periodically. The “Last Updated” date above reflects the latest revision. Significant changes will be posted here and, where appropriate, communicated by other means.

13. Contact Us

Questions? Email support@davincigrowth.com or privacy@davincigrowth.com.