Last Updated: March 27, 2026

Purpose and Scope

Gawa Growth is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in connection with our website, services, and business operations.

Gawa operates as a business-to-business marketing services provider. In many cases, we process personal information on behalf of our clients, who act as the data controllers. This Privacy Policy applies to:

• visitors to our website
• business contacts, prospects, and clients
• individuals whose data may be processed through client-managed platforms to which Gawa has authorized access

This Privacy Policy does not apply to the data practices of our clients. Clients are responsible for their own privacy policies and legal compliance obligations.

Information We Collect

Information Collected Directly by Gawa

We may collect limited personal information, including:

• name
• business email address
• business phone number
• company name and job title
• communications submitted through forms, email, phone calls, or meetings

Information Collected Automatically

When you visit our website, we may automatically collect certain information, including:

• IP address
• browser type and device information
• pages viewed and website interaction data
• cookies and similar tracking technologies

Phone and SMS Consent

By providing your phone number and clicking “Get Started,” you consent to receive phone calls and/or SMS messages from Gawa and its affiliates using automated technology, including autodialed calls, prerecorded or artificial voice messages, and automated text messages, for marketing, advertising, and transactional purposes.

You agree that we may contact you at the telephone number you provide, even if it is listed on a federal or state Do Not Call registry. Consent is not a condition of purchase, and you may withdraw your consent at any time. Message frequency may vary. Message and data rates may apply.

For additional information, please review Gawa’s Text Messaging Terms and this Privacy Policy.

Client-Controlled Data

Gawa may access or process personal information stored in client-owned systems, such as CRM platforms, advertising platforms, and analytics tools, solely for the purpose of providing contracted services.

Such data:

• is collected and controlled by the client
• remains the client’s responsibility
• is accessed by Gawa only under contractual authorization and client instruction

How We Use Personal Information

We may use personal information to:

• provide, manage, and improve our services
• communicate with clients, prospects, and business contacts
• respond to inquiries and requests
• analyze website traffic, usage, and performance
• comply with legal, regulatory, and contractual obligations

Gawa does not use client-controlled data for its own independent marketing or commercial purposes.

Legal Bases for Processing (GDPR)

Where applicable under the General Data Protection Regulation (GDPR), Gawa processes personal data on one or more of the following legal bases:

• performance of a contract
• legitimate business interests
• compliance with legal obligations
• consent, where required by law

When acting on behalf of clients, Gawa processes personal data in accordance with applicable data processing agreements and documented client instructions.

Cookies and Tracking Technologies

We use cookies and similar technologies to:

• enable core website functionality
• analyze website traffic and performance
• support marketing and advertising activities

You can control cookies through your browser settings. Additional information about our use of cookies may also be provided through a cookie banner or similar notice.

Data Sharing and Disclosure

We may disclose personal information to:

• service providers and vendors acting on our behalf
• professional advisors, such as legal, accounting, or insurance providers
• government, regulatory, or law enforcement authorities when required by law or legal process

Gawa does not sell, rent, or otherwise monetize personal information.

Data Retention

We retain personal information only for as long as reasonably necessary to:

• fulfill the purposes described in this Privacy Policy
• comply with legal, regulatory, tax, accounting, or contractual obligations
• enforce our agreements and resolve disputes

Client-controlled data accessed through client systems is retained and deleted in accordance with client instructions and applicable agreements.

Your Privacy Rights

GDPR (EEA and UK Residents)

Subject to applicable law, you may have the right to:

• access your personal data
• request correction or deletion of your personal data
• restrict or object to certain processing
• request data portability

If your request relates to personal data controlled by one of our clients, please contact that client directly.

CCPA / CPRA (California Residents)

California residents may have the right to:

• know what personal information is collected, used, disclosed, or shared
• request deletion of personal information
• request correction of inaccurate personal information
• opt out of certain sharing practices, where applicable
• not be discriminated against for exercising privacy rights

Requests may be submitted to: hello@gawagrowth.com

Data Security

Gawa implements reasonable administrative, technical, and organizational safeguards designed to protect personal information. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

International Data Transfers

Personal information may be transferred to and processed in the United States or other jurisdictions where privacy laws may differ from those in your location. Where required by applicable law, Gawa relies on appropriate safeguards, including standard contractual clauses or other lawful transfer mechanisms.

Children’s Privacy

Gawa’s services are not directed to children under the age of 13, or under 16 where required by applicable law. We do not knowingly collect personal information from children.

Contact Information

Gawa Growth
Email: hello@gawagrowth.com

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Anti-Spam and Unsolicited Advertising Policy

Effective Date: March 27, 2026
Last Updated: March 27, 2026

Purpose

Gawa Growth is committed to ethical, permission-based marketing and communications. This Anti-Spam and Unsolicited Advertising Policy outlines our prohibition against the use of unsolicited messages, or “spam,” to advertise or promote our website, services, or brand.

Scope

This policy applies to all employees, contractors, partners, vendors, and third-party representatives acting on behalf of Gawa Growth in connection with marketing, advertising, sales, or outreach activities.

Policy Statement

Gawa Growth prohibits the use of unsolicited communications, including email, SMS, social media direct messages, or other digital communications, to advertise or promote gawagrowth.com or any of our services.

We are committed to complying with all applicable anti-spam and privacy laws and regulations, including, where applicable:

• the CAN-SPAM Act of 2003 (United States)
• Canada’s Anti-Spam Legislation (CASL)
• the General Data Protection Regulation (GDPR)
• other applicable local, state, national, and international laws

Prohibited Activities

The following activities are strictly prohibited:

• sending unsolicited marketing emails or messages to individuals or organizations who have not expressed interest in our services
• using purchased, rented, harvested, or scraped contact lists
• misrepresenting the sender, source, or origin of any communication
• using false, deceptive, or misleading header information or subject lines
• sending messages without a clear and functional unsubscribe or opt-out mechanism, where required
• promoting our website or services through unauthorized or abusive tactics, including spam in forums, blogs, comment sections, or social media groups

Acceptable Marketing Practices

Gawa Growth supports ethical, transparent, and permission-based marketing practices, including:

• email marketing to recipients who have explicitly opted in or where communication is otherwise legally permitted
• content marketing, SEO, and organic social media engagement
• paid advertising through authorized platforms and channels
• professional outreach conducted with transparency, relevance, and respect for applicable laws and platform rules

Enforcement and Accountability

All employees, contractors, and partners are expected to comply with this policy. Violations may result in:

• disciplinary action for employees
• termination of contracts or business relationships
• legal action where warranted

Reporting Violations

Suspected violations of this policy should be reported promptly to Gawa Growth using the contact information listed below.

Policy Review

This policy will be reviewed periodically and updated as necessary to reflect changes in applicable laws, regulations, and best practices.

Contact Information

For questions regarding this policy, please contact:

Gawa Growth
Email: hello@gawagrowth.com
Website: www.gawagrowth.com