Privacy Policy

1. Who We Are

GrowthPicks Ltd is a company incorporated in Jersey, Channel Islands. We operate the GrowthPicks service at growthpicks.org.

We are registered with the Jersey Office of the Information Commissioner (JOIC) under registration number 103668.

For any questions about this Privacy Policy or how we handle your data, contact us at support@growthpicks.org.

2. What Data We Collect

We collect only what is necessary to provide the Service:

• Account information — your email address and a securely hashed password, collected when you register for an account. We never store your password in plain text.
• Portfolio data — if you use the Portfolio feature, we store the tickers and percentage weights you enter. We do not collect or store any dollar values, account balances, or financial account information.
• Usage data — basic analytics about how you interact with the Service, such as pages visited and features used. This data is collected in aggregate and is not used to build individual profiles.

We do not collect sensitive personal data such as financial account numbers, national identity numbers, health information, or biometric data.

3. How We Use Your Data

We use the data we collect to:

• Provide and maintain your account and access to the Service
• Send transactional emails (account confirmation, password resets)
• Send subscription content and service emails that form part of the Service, including our publication The Pulse, and notify you of changes to the Service or these terms
• Display your portfolio data back to you within the Service
• Monitor and improve the reliability and performance of the Service
• Comply with legal obligations

We do not sell, rent, or share your personal data with third parties for their marketing purposes. We do not use your data for advertising or ad targeting.

4. Legal Basis for Processing

We process your personal data on the following bases under the Data Protection (Jersey) Law 2018:

• Contract — processing necessary to provide the Service you have signed up for (account management, portfolio features, transactional emails, and delivery of subscription content such as The Pulse)
• Legitimate interests — monitoring service performance, improving the Service, and protecting against misuse
• Legal obligation — where we are required to retain or disclose data by law

5. Third-Party Services

We use a limited number of third-party services to operate GrowthPicks. These services process your data only as necessary to provide their function:

• Supabase (authentication and database) — stores your account credentials and portfolio data. Data is hosted on Supabase's infrastructure with encryption at rest and in transit.
• Resend (email delivery) — processes your email address to deliver transactional emails (such as account confirmation and password resets) and subscription content and service emails (such as our publication The Pulse). You can opt out of subscription content emails at any time via the unsubscribe link in those emails; opting out does not affect your access to subscriber content on the website.
• Vercel (web hosting) — serves the GrowthPicks web application. Vercel may process standard web server logs including IP addresses and browser information.

We do not use advertising networks, tracking pixels, or social media tracking tools.

6. Cookies

GrowthPicks uses only essential cookies required for the Service to function. Specifically, we use a session cookie to keep you logged in. We do not use advertising cookies, analytics cookies, or third-party tracking cookies.

7. Data Retention

We retain your account data for as long as your account is active. If you delete your account, we will delete your personal data within 30 days, except where we are required by law to retain it.

Portfolio data you enter is deleted immediately when you remove individual holdings, and fully deleted when your account is closed.

8. Data Security

We take reasonable measures to protect your data, including encryption in transit (HTTPS), encrypted storage, and access controls. However, no method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

9. International Data Transfers

GrowthPicks Ltd is based in Jersey, Channel Islands. Our third-party service providers may process data in other jurisdictions, including the United States. Where data is transferred outside Jersey, we ensure appropriate safeguards are in place in accordance with the Data Protection (Jersey) Law 2018.

10. Your Rights

Under the Data Protection (Jersey) Law 2018, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — ask us to correct inaccurate data
• Erasure — ask us to delete your data (subject to legal obligations)
• Restriction — ask us to limit how we process your data
• Objection — object to processing based on legitimate interests
• Portability — receive your data in a structured, machine-readable format

To exercise any of these rights, contact us at support@growthpicks.org. We will respond within 30 days.

If you are unsatisfied with how we handle your data, you have the right to lodge a complaint with the Jersey Office of the Information Commissioner (JOIC) at jerseyoic.org.

11. Children

The Service is not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will take steps to delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email. The "Last Updated" date at the top of this page indicates when the policy was last revised.

13. Contact

For any questions about this Privacy Policy or to exercise your data rights:

GrowthPicks Ltd
Jersey, Channel Islands
JOIC Registration: 103668
support@growthpicks.org