How we collect, use, and protect your personal data — and the terms governing our services.
This privacy policy (“Policy”) describes how D2 Direct T/A Growth Begins Here, 23 King Street, Cambridge, CB1 1AH (“Company,” “we,” “us,” “our,” “controller”) processes, collects, uses and shares personal data when using www.growthbeginshere.com (the “Site”). Please read the following information carefully to understand changes to our practices regarding your personal data*, including GDPR compliance, how we will process data and the changes we made to it.
*Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
While visiting this site you will have the option to consent (opt-in) to receive further information and to be contacted by us or one of our affiliates. By opting in, you are granting us the permission to collect and process information supplied by the data subject, you, for the purpose of contacting you with offers, promotional materials and other related information about income opportunities and related products. This data may be shared with affiliates of D2 Direct T/A Growth Begins Here and/or third-party sites as listed herein.
Data may include the subject’s name, email address, IP address, phone number, or other information as supplied by the data subject.
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
We may also collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
In addition, we may use third-party services such as Google Analytics that collect, monitor and analyse this type of information in order to increase our Service’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.
Each data subject shall have the following rights with regard to the personal data concerning them. They can action their rights, without undue delay, by contacting the Site (the Controller). The Controller will carry out all requests pursuant to GDPR compliance without undue wait.
Each data subject shall have the right to confirm whether or not personal data concerning him or her is being processed.
Each data subject shall have the right to receive free information about his or her personal data stored at any time and a copy of this information.
Each data subject has the right to file a complaint against the Controller with a supervisory authority pursuant to GDPR law.
The data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
The data subject has the right to withdraw consent to which the processing is based and where there is no other legal ground for the processing.
In certain circumstances per GDPR law, each data subject shall have the right to obtain from the controller restriction of processing.
Each data subject shall have the right to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Each data subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her. This also applies to profiling based on these provisions. The data subject is free to use his or her right to object by automated means using technical specifications.
The Site does not process any data resulting from profiling.
Each data subject has the right to withdraw consent to the processing of personal data at any time.
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We use cookies to collect information in order to improve our services for you.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.
If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.
Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
As a responsible company, we do not use automatic decision-making or profiling; however, our company does use remarketing services, in accordance with GDPR law, to advertise on third-party websites to you after you have visited our Service. We, and our third-party vendors, use cookies to inform, optimise and serve ads based on your past visits to our Service.
On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting: https://www.facebook.com/help/164968693837950
To opt out from Facebook’s interest-based ads, follow these instructions: https://www.facebook.com/about/ads/
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the Digital Advertising Alliance in the USA, the Digital Advertising Alliance of Canada, or the European Interactive Digital Advertising Alliance in Europe, or opt out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit: Facebook’s Privacy Policy
An overview of all Facebook Plug-ins may be accessed at: https://developers.facebook.com/docs/plugins/
On this website, the controller may have integrated Google AdSense. Google AdSense is an online service which allows the placement of advertising on third-party sites. Google AdSense is based on an algorithm that selects advertisements displayed on third-party sites to match with the content of the respective third-party site. Google AdSense allows an interest-based targeting of the Internet user, which is implemented by means of generating individual user profiles.
The operating company of Google’s AdSense component is Alphabet Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The data subject may prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Alphabet Inc. from setting a cookie on the information technology system of the data subject. Additionally, cookies already in use by Alphabet Inc. may be deleted at any time via a web browser or other software programs.
Furthermore, Google AdSense also uses so-called tracking pixels. Through Google AdSense, personal data and information—which also includes the IP address, and is necessary for the collection and accounting of the displayed advertisements—is transmitted to Alphabet Inc. in the United States of America. These personal data will be stored and processed in the United States of America. Alphabet Inc. may disclose the collected personal data through this technical procedure to third parties.
Google AdSense is further explained at: https://www.google.com/intl/en/adsense/start/
On this website, the controller may have integrated the component of Google Analytics (with the anonymiser function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application “_gat._anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.com/intl/en/policies/privacy/ and at http://www.google.com/analytics/terms/us.html. Google Analytics is further explained at: https://www.google.com/analytics/
On this website, the controller may have integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.
The operating company of the Google Remarketing services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.
The personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
Further information and the actual data protection provisions of Google may be retrieved at: https://www.google.com/intl/en/policies/privacy/
On this website, the controller may have integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results is only then displayed when the user utilises the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
The data subject has a possibility of objecting to the interest-based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved at: https://www.google.com/intl/en/policies/privacy/
On this website, the controller may have integrated the Google+ button as a component. Google+ is a so-called social network. A social network is a social meeting place on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space.
The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, the Internet browser on the information technology system of the data subject automatically downloads a display of the corresponding Google+ button of Google through the respective Google+ button component.
If the data subject does not wish to transmit personal data to Google, he or she may prevent such transmission by logging out of his Google+ account before calling up our website.
Further information and the data protection provisions of Google may be retrieved at: https://www.google.com/intl/en/policies/privacy/. More references from Google about the Google+ 1 button may be obtained at: https://developers.google.com/+/web/buttons-policy
On this website, the controller may have integrated components of the service Instagram. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos, as well as disseminate such data in other social networks.
The operating company of the services offered by Instagram is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, United States.
Instagram receives information via the Instagram component that the data subject has visited our website provided that the data subject is logged in at Instagram at the time of the call to our website. This occurs regardless of whether the person clicks on the Instagram button or not. If such a transmission of information to Instagram is not desirable for the data subject, then he or she can prevent this by logging off from their Instagram account before a call-up to our website is made.
Further information and the applicable data protection provisions of Instagram may be retrieved at: https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/
The controller may have integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States. For privacy matters outside of the United States, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.
LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy.
On this website, the controller may have integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages. These short messages are available for everyone, including those who are not logged on to Twitter.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States.
Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.
The applicable data protection provisions of Twitter may be accessed at: https://twitter.com/privacy?lang=en
On this website, the controller may have integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, United States. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.
YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.
We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We may employ third-party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services and/or to assist us in analysing how our Service is used.
These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.
We may use your Personal Information to contact you with newsletters, emails, marketing or promotional materials and other information you consented to receive. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We will disclose your Personal Information in accordance with GDPR compliance where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.
The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorised access, destruction, use, modification, or disclosure.
However, please be aware that no method of transmission over the Internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.
In the case of a personal data breach, we will, without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.
Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to the United States and process it there.
When giving consent you are agreeing to and acknowledging the transfer of your data.
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller.
If the data controller concludes an independent contract with an applicant, the submitted data will be stored for the purpose of processing the contractual relationship in compliance with legal requirements. If no contract is concluded with the applicant by the controller, the application documents shall be automatically erased within a one-month time period, provided that no other legitimate interests of the controller are opposed to the erasure.
Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Only persons aged 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us with your request to erase the data. We will erase the data without undue wait.
If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we will remove the data without undue wait.
This Privacy Policy is effective as of 24 May 2018 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. If we make any material changes to this Privacy Policy, we will notify you by email to the address you have provided us.
Continued use of the Service after we post any modifications to the Privacy Policy will require your consent.
D2 Direct T/A Growth Begins Here (“Growth Begins Here,” “We,” “Us,” “Our”) provides various business coaching services, products, and goods through this Website (the “Service”). This Service is offered subject to Your acceptance of these Terms as well as any relevant sections of this Policy.
Please read these notice, terms, and conditions (“Terms”) carefully before using Our Service.
The first step in our process is a phone interview to determine your suitability for our services. The interview process is conducted over the phone with a professional consultant from D2 Direct T/A Growth Begins Here and if you qualify at the point of interview the initial Information Pack, or Business Presentation is provided to you free of charge.
The Business Presentation is provided to you electronically and presented in a series of educational videos.
You must be at least 18 years old to access this Website or to purchase products and/or Services from Us.
You agree that you are accessing the Services on Our Website for business purposes. If you are using the Service on behalf of an organization, You are agreeing to these Terms for that organization and confirming now to D2 Direct T/A Growth Begins Here that you have the authority to bind said organization to Our Terms of Service (in which event, “You” and “Your” will refer to that organization).
If you do not agree with these Terms, or are under 18 years old, please do not use the Services or Our Website. If at any time you are not willing to be bound by these Terms, You should:
Upon approval of your application and invitation and as part of the registration or account creation process, You will create personally identifying login credentials. Certain personally identifying information, such as email address, phone number, billing address and even payment information (as may be applicable to particular Services which may be offered for sale via this Website), may also be required. Such registration information must be accurate and current.
The benefits, rights, and obligations afforded under these Terms are personal to You. You agree not to assign, sublicense, transfer, pledge, sell, lease, rent, lend, or otherwise dispose of the Services and materials (including, but not limited to, audio and/or visual presentations, documentation, software, printed or digital materials, and other elements characterizing Our Services, also known as the “Content”) on this Website, or any part of such Content on our partnering sites, or share your rights under these Terms to and with others.
You agree that You will not provide false information to Us in generating Your account. Specifically, You agree that you will not:
Failure to comply with the foregoing shall constitute a breach of these Terms, which may result in immediate suspense or termination of your account.
Only authorized users, who have duly attained access to the Content by personally agreeing to these Terms are permitted participation in and use of the Services, Content, and related materials. Except as expressly authorized by these Terms, You shall not provide or make available any Content, or any license key to any third party, or use the Content, or any license key, to teach any third party any portion of the Services or for any purpose other than exercising rights expressly granted to you by these Terms.
You are responsible for maintaining the confidentiality of Your login credentials. We reserve the right to terminate or suspend Your access to the Services if You share Your credentials or transfer such credentials to another party.
You are responsible for all usage or activity on your account on this Website and related Social Media, including use of the account by any third party authorized by you to use your login credentials.
We have an unconditional 14 day money back guarantee on every service we offer. No questions, no hassles. Just your money back within the refund period.
By accepting these Terms, You agree and understand that We provide seminars and business coaching services only and guarantee no specific results. You acknowledge that We make no promise or representation that You will make a certain amount of money, or any money, or that you will not lose money, as a result of using these Services.
Any earnings, revenue, or income statements viewable on this Website or our related Social Media are based on actual individual results of our clients and/or estimates as may be stated. There is no guarantee that you will make these levels for yourself. As with any business, Your results will vary and will be based on your personal abilities, experience, knowledge, capabilities, level of desire, and an infinite number of variables beyond Our control, including some variables that neither We nor You may have anticipated. There are no guarantees concerning the level of success You may experience. Each person’s results will vary.
There are unknown risks in any business, particularly with the Internet where advances and changes can happen quickly. The use of our information, products and services should be based on your own due diligence and You agree that We are not liable for Your success or failure.
In accepting these Terms, You acknowledge that You take full responsibility for your own success.
Limitations herein described shall be applied to the greatest extent enforceable under applicable law.
By accepting these Terms, you agree that We may collect, use and disclose your identifying information obtained as a result of Your membership, for the following purposes:
Please visit the Privacy Policy section above for further details on our data protection policy, including how You may access and correct your personal information or withdraw consent to the collection, use or disclosure of your personal information.
Additionally when You communicate with Us, send Us information, or provide Content to Us, You grant Us a non-exclusive, worldwide, perpetual, royalty-free right to exercise all copyright and publicity rights that You have in such Content, in any manner whatsoever, in any media now known or which may be created in the future, as relates to this Website, the Services, and related Social Media.
The contents of the Services, including the Website, Content, and other materials made available via related Social Media, are protected by copyright, trademark and other intellectual property laws and international treaties and owned or controlled by D2 Direct T/A Growth Begins Here, or the party credited as the provider of the Content. You agree to abide by all additional copyright notices, information, or restrictions contained in any Content accessed through the Services.
By accepting these Terms, You further acknowledge and agree that We and Our third party licensors own and shall continue to own all right, title, and interest in and to the Content and other elements of Our Services, including associated intellectual property rights under copyright, trade secret, patent, or trademark laws.
Except for any limited, revocable license expressly granted to you herein, these Terms do not grant you any ownership or other right or interest in or to the Content and/or other elements of the Services, or any other intellectual property rights of Ours, whether by implication, estoppel, or otherwise. Any and all trademarks or service marks that We use in connection with the Services are marks owned by Us. These Terms do not grant you any right, license, or interest in such marks, and you shall not assert any right, license, or interest in such marks or any words or designs that are confusingly similar to such marks.
You may not modify, publish, transmit, participate in the transfer or sale of, reproduce (except where expressly permitted for the storage of downloadable material), create new works from, distribute, perform, display, or in any way exploit, any of the Content or the Services (including software) in whole or in part.
We may elect to terminate the Services on this Website at Our discretion without notice to You or any liability for any reasons whatsoever, including without limitation, if You breach these Terms. You may terminate any account You establish via this website at any time upon written notice to Us.
These Terms may not be modified or amended orally, impliedly, or in any manner not set forth in a duly executed writing or otherwise permitted by these Terms.
We reserve the right to modify, terminate, or otherwise amend Services available via this Website and related Social Media accounts. We may, in the future, offer new and/or different services and/or features through its Website and associated Social Media accounts. Such new features and/or services shall be subject to these Terms.
Our failure to enforce any rights granted by these Terms or to take action against any other party in the event of any breach shall not be deemed a waiver by Us as to subsequent enforcement of rights or subsequent actions in the event of future breaches.
These Terms in all respects shall be governed by and construed according to the laws of the State of Arizona. The venue for any dispute shall be in the County of Maricopa.
This Agreement is entered into in Maricopa, Arizona. You agree and consent to the exclusive jurisdiction and venue of the state of Arizona and county of Maricopa for any dispute arising from or related to this Agreement.
Should any part of these Terms be declared void or unenforceable, that term shall be severed from these Terms and such declaration shall have no effect on the enforceability of the remaining terms.
If you have any questions regarding this Privacy Policy, our Terms and Conditions, or any other matter, please do not hesitate to contact us.
support@growthbeginshere.comD2 Direct T/A Growth Begins Here
23 King Street, Cambridge, CB1 1AH