Privacy Policy

Privacy Policy

K&G Growth Solutions Privacy Policy

Effective Date: 1 May 2025
Last Updated: 19 September 2025

At K&G Growth Solutions (“Company”, “we”, “our”, or “us”), we are committed to protecting your privacy and safeguarding your personal data. This Privacy Policy explains how we collect, use, store, and protect information when you access or use our websites, platforms, and services (collectively, the “Services”).

We operate under a privacy-first, sovereignty-by-design philosophy. Data is never treated as a commodity, but as a responsibility.

1. Data Controller

The data controller responsible for processing your personal data is:

K&G Growth Solutions
Hart van Brabantlaan 12
5038 JT Tilburg
The Netherlands
📧 contact@kggrowthsolutions.com

2. Information We Collect

We may collect the following categories of data:

a. Personal Identification Data

  • Name

  • Email address

  • Phone number

  • Company or organization

  • Billing and invoicing details

b. Technical & Usage Data

  • IP address

  • Browser type and version

  • Device identifiers

  • Operating system

  • Pages visited, session duration, and interaction patterns

c. AI Intake & System Data (Where Applicable)

If you use MindLayer.AI or related intake systems:

  • Intake responses are processed in anonymized or pseudonymized form

  • No biometric, medical, or psychological diagnosis data is collected

  • Data is processed strictly within the S6 Sovereignty Framework (see Section 4)

We do not collect data that is unnecessary for lawful operation.

3. How We Use Your Information

We process personal data lawfully and transparently for the following purposes:

  • To provide, operate, and improve our Services

  • To manage onboarding, subscriptions, and contractual obligations

  • To secure platforms, prevent fraud, and protect digital infrastructure

  • To ensure lawful, ethical, and compliant system operation

  • To personalize user experience without behavioral manipulation

  • To comply with legal and regulatory obligations

We do not sell, trade, or exploit personal data.

Where Services involve the delivery of digital reportsor reflective reports by email, users are responsible for ensuring correct email details and for checking spam or junk folders. K&G Growth Solutions cannot guarantee delivery where third-party email systems block or delay messages.

4. S6 Sovereignty & AI Governance Framework

All AI-assisted systems operated by K&G Growth Solutions — including MindLayer.AI, digital intake systems, and decision-support tools — function under our S6 Sovereignty Framework.

This framework ensures that:

  • Human autonomy is preserved at all times

  • AI systems support, but never replace, human judgment

  • No emotional, psychological, or behavioral manipulation occurs

  • No dependency-creating mechanisms are used

  • AI outputs are advisory, not directive

Explicitly Excluded Uses

We do not use AI systems for:

  • Automated decision-making with legal or significant personal impact (GDPR Art. 22)

  • Psychological profiling for persuasion or control

  • Predictive behavioral manipulation

  • Surveillance-based influence systems

Human oversight is always present.
AI exists as structure, not authority.

K&G Growth Solutions does not engage in automated decision-making or profiling that produces legal or similarly significant effects within the meaning of Article 22 GDPR.

5. Legal Basis for Processing (GDPR)

We process personal data under one or more of the following legal grounds:

  • Consent – where explicitly provided

  • Contractual necessity – to deliver agreed Services

  • Legitimate interest – to secure, improve, and maintain our systems

  • Legal obligation – to comply with EU or Dutch law

6. Data Retention

We retain personal data only as long as necessary:

  • Account and billing records: up to 7 years (Dutch tax law)

  • AI intake data: anonymized or deleted after defined retention periods

  • Technical and cookie data: typically 12 months

When data is no longer required, it is securely deleted or irreversibly anonymized.

7. Sharing of Data

We do not sell personal data.

Data may be shared only with:

  • Trusted service providers (hosting, payment processing, analytics)

  • Legal authorities when legally required

  • Contracted partners under strict confidentiality agreements

All third parties are bound by data protection obligations equivalent to ours.

K&G Growth Solutions does not sell or share personal data as defined under applicable U.S. privacy laws, including the California Consumer Privacy Act (CCPA/CPRA).

8. International Data Transfers

If personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards, including:

  • EU Standard Contractual Clauses (SCCs)

  • Equivalent legal protections

9. Your Rights Under GDPR

You have the right to:

  • Access your personal data

  • Correct inaccurate or incomplete data

  • Request deletion (“right to be forgotten”)

  • Restrict or object to processing

  • Data portability

  • Withdraw consent at any time

Requests can be submitted via:
📧 contact@kggrowthsolutions.com

10. Cookies & Tracking

We use cookies and similar technologies to:

  • Improve website performance

  • Analyze traffic and usage patterns

You may manage or disable cookies through your browser settings.

11. Data Security

We implement technical and organizational measures including:

  • Encryption

  • Access controls

  • Secure custody frameworks

  • Compliance-first system architecture

While no system is 100% secure, we continuously evolve our protections.

12. Children’s Privacy

Our Services are not directed at individuals under 16 years of age.
We do not knowingly collect personal data from children.

13. Updates to This Policy

This Privacy Policy may be updated periodically.
Changes will be published on this page with an updated revision date.

Final Principle

Privacy is not a feature.
It is infrastructure.
And sovereignty begins with control over one’s data.

For questions or complaints about this Privacy Policy:

K&G Growth Solutions
Hart van Brabantlaan 12
5038 JL Tilburg
The Netherlands
📧 contact@kggrowthsolutions.com