A DIFFERENT APPROACH

Privacy Policy

At Smart Money Growth, we take your privacy seriously. This document outlines exactly how we handle your data, from our diagnostic tools to our newsletters, ensuring full compliance with GDPR and Luxembourg data protection laws.

PRIVACY POLICY
Effective Date: 16 January 20261. Introduction
Smart Money Growth ("we," "us," or "our") is an educational practice based in Luxembourg dedicated to providing financial literacy and investment frameworks. We respect your privacy and are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR).This policy explains how we collect, use, and protect your information when you visit our website, download our resources, or apply for our programs.2. Who Is Responsible (Data Controller)
The data controller responsible for your information is:
Romain Lucas (trading as Smart Money Growth)
Location: Luxembourg
Contact: [email protected]3. What Data We Collect
We collect limited personal data necessary to deliver our educational services.* Identity Data: First name, last name.
* Contact Data: Email address.
* Technical Data: IP address, browser type, time zone, and usage data (via cookies).
* Application Data: Information you voluntarily provide when applying for the "Strategic Session" or "Mastery Program" (e.g., investment goals, current portfolio status).4. Legal Bases & How We Use Your Data
Under GDPR Article 6, we must have a legal basis for processing your data. We rely on the following:* To Deliver Assets: Sending guides ("Clarity Guide") you requested.
(Data used: Identity, Contact | Legal Basis: Consent)* To Educate: Sending the "Rational Investor" newsletter.
(Data used: Identity, Contact | Legal Basis: Consent or Legitimate Interest)* To Process Applications: Reviewing suitability for mentorship.
(Data used: Application Data | Legal Basis: Contractual Obligation)* To Improve Service: Website analytics (GA4).
(Data used: Technical Data | Legal Basis: Consent)* To Market: Retargeting ads (Meta Pixel).
(Data used: Technical Data | Legal Basis: Consent)Our "Zero Sale" Promise:
We are an unconflicted education practice. We never sell, rent, or trade your personal data to third parties, banks, or financial institutions.5. Third-Party Processors & International Transfers
We use trusted third-party service providers to operate our business. Some of these providers (e.g., Google, Meta, Notion) are based in the United States. When data is transferred outside the European Economic Area (EEA), we ensure it is protected through Standard Contractual Clauses (SCCs) or the Data Privacy Framework (DPF).* Carrd: Website hosting.
* MailerLite: Email marketing and newsletter delivery.
* Stripe: Secure payment processing (we do not store credit card details).
* Google Analytics (GA4): Anonymous website traffic analysis.
* Meta (Facebook/Instagram): Ad performance tracking (via Pixel).
* Notion: Internal client relationship management (CRM).6. Data Retention
We only retain your personal data for as long as necessary to fulfill the purposes we collected it for:* Marketing/Newsletter Data: Kept until you unsubscribe. We review inactive subscribers every 24 months.
* Client Data: Kept for the duration of our mentoring relationship plus the statutory limitation period required by Luxembourg tax laws (usually 10 years for accounting records).
* Application Data: If you do not join a program, data is deleted after 12 months.7. Your Rights
Under the GDPR, you have the following rights:* Right to Access: Request a copy of the data we hold about you.
* Right to Rectification: Ask us to correct inaccurate data.
* Right to Erasure: Ask us to delete your data ("Right to be Forgotten").
* Right to Withdraw Consent: You can unsubscribe from our emails at any time via the link in the footer.To exercise these rights, email [email protected].If you believe we have infringed your rights, you have the right to lodge a complaint with the Luxembourg supervisory authority: Commission Nationale pour la Protection des Données (CNPD).8. Cookies & Tracking (Analytics & Ads)
We use cookies to enhance your experience and measure marketing effectiveness.* Google Analytics 4 (GA4): We use GA4 to understand website traffic. IP addresses are anonymized.
* Meta Pixel: We use the Meta Pixel to measure the effectiveness of our advertising and to serve relevant ads to you on Facebook/Instagram based on your visits to our site.Cookie Control:
When you first visit our site, you will see a cookie banner. We only fire non-essential cookies (Analytics/Marketing) if you click "Accept." You can withdraw this consent at any time via your browser settings.9. Changes to This Policy
We may update this privacy policy to reflect changes in our practices or legal requirements.
Last Updated: 16 January 2026