Privacy Policy

Last Updated: September 19, 2026

1. Who We Are

GrowthPicks Ltd is a company incorporated in Jersey, Channel Islands, company number 164938. 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.
  • Subscription information: if you take out a paid subscription, we store your plan, your subscription status, the relevant dates (such as when a trial ends or a period renews), and the subscription reference issued by our payment provider. We do not receive or store your card or bank details. Those go directly to the payment provider.
  • Mailing list information: if you join our mailing list, with or without an account, we store your email address, when and where on the site you signed up, and a record of the consent you gave.
  • Usage data: cookie-free, aggregate analytics about how the Service is used, such as pages visited and the site a visitor came from. This data is not linked to your account 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
  • Manage your subscription, including confirming its status with our payment provider
  • 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
  • Send mailing list emails if you have opted in, including anything you asked for when you joined, such as a free guide
  • 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, subscription management, portfolio features, transactional emails, and delivery of subscription content such as The Pulse)
  • Consent: sending mailing list emails to people who have opted in. You can withdraw your consent at any time using the unsubscribe link in any of those emails, or by contacting us.
  • 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, subscription records, mailing list records, 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), subscription content and service emails (such as our publication The Pulse), and mailing list emails. 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.
  • PayPal (payments): takes subscription payments and handles your card or bank details. PayPal tells us whether your subscription is in trial, active, paused, or cancelled. We never see your full payment details. PayPal handles payment data under its own privacy statement.
  • Vercel (web hosting): serves the GrowthPicks web application. Vercel may process standard web server logs including IP addresses and browser information.
  • Plausible Analytics (usage analytics): provides the cookie-free, aggregate analytics described above. Plausible does not use cookies and does not store information that identifies you.

We do not place advertising or social media tracking pixels on the Service, and we do not share your personal data with advertising networks.

6. Cookies

GrowthPicks uses only essential cookies and similar browser storage required for the Service to function. Specifically, we store a session token in your browser to keep you logged in. We do not use advertising cookies or analytics cookies. When you open the subscription page, our payment provider's checkout loads and may set its own cookies, which it uses for security and fraud prevention.

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.

Subscription records are kept while your account exists, and afterwards only where we need them for accounting or legal reasons. If you leave the mailing list, we stop emailing you and keep only the record needed to make sure we do not email you again.

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
Company number 164938, registered in Jersey, Channel Islands
JOIC Registration: 103668
support@growthpicks.org