Privacy Policy

Privacy Policy

K&G Growth Solutions Privacy Policy

Effective Date: 1 May 2025
Last Updated: 27 September 2026

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”).

MindLayer and any other named offerings are services operated by K&G Growth Solutions and are not separate legal entities.

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
Sole proprietorship (eenmanszaak)
Netherlands Chamber of Commerce (KvK): 69080372
VAT identification number: NL001684779B05
Burgemeester van Hoofflaan 73
5503 BK Veldhoven
The Netherlands
Email: 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 and Usage Data

  • IP address

  • Browser type and version

  • Device identifiers

  • Operating system

  • Pages visited, session duration, and interaction patterns

c. AI Intake and System Data

Where applicable, if you use MindLayer or related intake systems:

  • Intake responses may be processed in anonymized or pseudonymized form.

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

  • Data is processed within the S6 Sovereignty Framework, as described in Section 4.

We do not collect personal data that is unnecessary for the lawful operation of our Services.

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 the 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 or reflective reports by email, users are responsible for providing accurate email details and checking their spam or junk folders.

K&G Growth Solutions cannot guarantee delivery where third-party email systems block or delay messages.

4. S6 Sovereignty and AI Governance Framework

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

MindLayer is a service operated by K&G Growth Solutions and is not a separate legal entity.

The framework is intended to ensure that:

  • Human autonomy is preserved.

  • AI systems support, but do not replace, human judgment.

  • No emotional, psychological, or behavioral manipulation occurs.

  • No dependency-creating mechanisms are used.

  • AI-generated outputs are advisory and not directive.

Explicitly Excluded Uses

We do not use AI systems for:

  • Automated decision-making that produces legal or similarly significant personal effects, as described in Article 22 of the GDPR

  • Psychological profiling for persuasion or control

  • Predictive behavioral manipulation

  • Surveillance-based influence systems

Human oversight remains 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 of the GDPR.

5. Legal Basis for Processing

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

  • Consent — where consent has been explicitly provided

  • Contractual necessity — where processing is required to provide agreed Services or take requested pre-contractual steps

  • Legitimate interests — where processing is necessary to secure, improve, and maintain our Services, provided those interests do not override your rights

  • Legal obligations — where processing is required under Dutch or European law

6. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected or as required by law.

Indicative retention periods include:

  • Account and billing records: up to seven years, where required under Dutch tax law

  • AI intake data: deleted or anonymized after the applicable retention period

  • Technical and cookie data: generally retained for no longer than necessary and in accordance with our Cookie Policy

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

7. Sharing of Data

We do not sell personal data.

Personal data may be shared only with:

  • Trusted service providers supporting functions such as hosting, payment processing, communications, security, and analytics

  • Public authorities where disclosure is legally required

  • Contracted professional or operational partners subject to appropriate confidentiality and data-protection obligations

Where required, we enter into data-processing agreements with service providers that process personal data on our behalf.

K&G Growth Solutions does not sell or share personal data as those terms are defined under applicable United States privacy laws, including the California Consumer Privacy Act and California Privacy Rights Act.

8. International Data Transfers

Where personal data is transferred outside the European Economic Area, we implement appropriate safeguards as required by applicable data-protection law.

These safeguards may include:

  • European Commission adequacy decisions

  • European Union Standard Contractual Clauses

  • Supplementary technical and organizational safeguards

  • Other legally recognized transfer mechanisms

9. Your Rights Under the GDPR

Subject to applicable legal requirements and exceptions, you may have the right to:

  • Access your personal data

  • Correct inaccurate or incomplete personal data

  • Request deletion of your personal data

  • Restrict the processing of your personal data

  • Object to certain processing activities

  • Receive applicable personal data in a portable format

  • Withdraw consent at any time, without affecting processing performed before withdrawal

  • Request information about applicable automated decision-making

Requests can be submitted to:

contact@kggrowthsolutions.com

We may need to verify your identity before processing a request.

You also have the right to lodge a complaint with the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens
www.autoriteitpersoonsgegevens.nl

10. Cookies and Tracking

We may use cookies and similar technologies to:

  • Enable necessary website functionality

  • Remember relevant preferences

  • Improve website performance

  • Analyze traffic and usage patterns

  • Protect the security and integrity of our websites

Where legally required, optional cookies are placed only after consent has been provided.

For detailed information about the cookies we use, their purposes, providers, and retention periods, please consult our Cookie Policy (EU).

You may provide, refuse, or withdraw cookie consent through the cookie settings available on our website.

11. Data Security

We implement appropriate technical and organizational measures designed to protect personal data.

These measures may include:

  • Encryption

  • Access controls

  • Secure hosting and data-storage measures

  • Data minimization

  • Confidentiality obligations

  • Compliance-oriented system architecture

  • Security monitoring and incident-management procedures

Although no system can guarantee absolute security, we continuously review and improve 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 under the age of 16. If we learn that such data has been collected, we will take appropriate steps to delete it.

13. Updates to This Policy

This Privacy Policy may be updated periodically to reflect changes to our Services, processing activities, or legal obligations.

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, requests, or complaints concerning this Privacy Policy:

K&G Growth Solutions
Sole proprietorship (eenmanszaak)
Netherlands Chamber of Commerce (KvK): 69080372
VAT identification number: NL001684779B05
Burgemeester van Hoofflaan 73
5503 BK Veldhoven
The Netherlands
Email: contact@kggrowthsolutions.com