Effective Date: 1 August 2025

Last Updated: July 2026

GrowthDesk (operated by CCLEATS (Pty) Ltd, hereinafter 'GrowthDesk', 'we', 'us', or 'our') is committed to protecting the privacy of every person who interacts with our website, services, and marketing communications.

This Privacy Policy explains what personal information we collect, how we use it, how we protect it, and what rights you have over it. It applies to all users of growthdesk.co.za, growthdesk.com, and any related forms, funnels, or automated communications we operate on your behalf.

By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy.

1. Who We Are

GrowthDesk is a done-for-you business automation agency serving South African solopreneurs and SMB owners. We help businesses capture leads, nurture prospects, and gain visibility over their revenue through a managed platform environment.

Operating entity: CCLEATS (Pty) Ltd

Primary domain: growthdesk.co.za

Contact email: [email protected]

Postal address: Cape Town, Western Cape, South Africa (full address available on request)

2. Information We Collect

2.1 Information You Provide Directly

- Full name and contact details (email address, phone number, WhatsApp number)

- Business name, website URL, and industry information

- Responses to our Business Temperature Check quiz and any onboarding forms

- Payment and billing information (processed securely via Netcash, Payfast, or Paystack — we do not store card details ourselves)

- Communications sent to us via email, WhatsApp, or any web form.

2.2 Information We Collect Automatically

- IP address, browser type, and device information when you visit our website

- Pages viewed, time spent, and click behaviour via standard web analytics

- Email open rates, click-through rates, and engagement data from our marketing sequences

- WhatsApp message delivery and response data within our automated workflows

2.3 Information From Third Parties

- Referral data from advertising platforms (Meta, Google, TikTok) if you arrive via a paid or boosted post

- Data you authorise us to access when connecting third-party tools during onboarding

3. How We Use Your Information

We use your personal information for the following purposes:

- To deliver and manage the services described in your service agreement

- To send you onboarding communications, workflow notifications, and platform updates

- To run automated email and WhatsApp nurture sequences relevant to your stage in our process

- To respond to your enquiries, support requests, and strategy call bookings

- To process payments and maintain accurate billing records

- To personalise your experience and tailor our communications to your business context

- To analyse the performance of our own marketing content for internal improvement

- To comply with our legal obligations under South African law

We will never sell your personal information to third parties. We do not use your data for unsolicited advertising beyond the communications you have opted into.

4. Legal Basis for Processing (POPIA)

Our processing of your personal information is grounded in the Protection of Personal Information Act, 4 of 2013 (POPIA). The specific lawful bases we rely on include:

Contractual necessity: to fulfil our service agreement with you.

Legitimate interests: to improve our services, manage our business, and communicate relevant offers.

Consent: for marketing communications and WhatsApp messaging sequences.

Legal obligation: where we are required to retain or disclose information under applicable law.

5. WhatsApp and Automated Messaging

GrowthDesk uses WhatsApp as its primary automated messaging channel in South Africa. By providing your WhatsApp number and opting into our services or lead capture forms, you consent to receiving automated WhatsApp messages as part of our onboarding, nurture, and client communication workflows.

You may opt out of WhatsApp messaging at any time by replying STOP or by contacting us directly. Opting out of WhatsApp messages does not affect your service agreement unless stated otherwise.

6. Sharing Your Information

Service delivery partners: We use a managed white-label platform to deliver our services. This platform processes data on our behalf under appropriate data processing agreements.

Payment processors: Netcash, Payfast, and Paystack receive billing information necessary to process your payments. These providers operate under their own privacy policies.

Professional advisors: Our accountants, legal advisors, and company secretarial service (Prosperity) may access limited information where required.

Legal requirements: We may disclose information if required by law, court order, or a regulatory authority.

All third parties with whom we share data are required to handle it securely and in accordance with applicable privacy law.

7. Data Retention

- Client records are retained for a minimum of five years following the end of a service agreement, for accounting and legal compliance purposes.

- Prospecting and lead data is retained for up to 24 months from the date of last engagement unless you request removal sooner.

- Marketing consent records are retained indefinitely unless consent is withdrawn.

On request, we will delete or anonymise your personal information where there is no overriding legal obligation to retain it.

8. Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, or disclosure. These include access controls on our platform environment, encrypted data transmission (HTTPS), and restricted internal access to sensitive records.

No digital system is entirely immune to security risks. We will notify you without undue delay if a data breach occurs that is likely to affect your rights.

9. Your Rights Under POPIA

- Access the personal information we hold about you

- Request correction of inaccurate or incomplete information

- Request deletion of your personal information (subject to legal retention requirements)

- Object to the processing of your information on grounds of legitimate interest

- Withdraw consent to marketing or automated messaging at any time

- Lodge a complaint with the Information Regulator of South Africa

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

Information Regulator: [email protected] · 012 406 4818

10. Cookies and Tracking

Our website uses cookies and similar tracking technologies to analyse traffic and improve your experience. You may adjust your browser settings to decline cookies, though this may affect certain site features.

We do not use cookies to build advertising profiles that are sold to third parties.

11. Children's Privacy

Our services are intended for business owners and are not directed at individuals under 18 years of age. We do not knowingly collect personal information from minors.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify active clients of material changes via email. The current version is always available at growthdesk.co.za/privacy-policy.

13. Contact Us

Email: [email protected]

Website: www.growthdesk.co.za

Operating entity: CCLEATS (Pty) Ltd, Cape Town, South Africa