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: 15 May 20261. Introduction
Smart Money Growth SARL-S ("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, register for our workshops, or apply for our programs.2. Who Is Responsible (Data Controller)
The data controller responsible for your information is:
Smart Money Growth SARL-S, represented by Romain Lucas
Registered Address: 14 Avenue Pasteur, L-2310 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. Phone number (optional, for workshop WhatsApp groups).
* 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).
* Workshop Data: Registration information and payment confirmation (handled by Stripe, we do not store card details) for paid workshops.
* Special Category Data (Dietary Restrictions): If you submit dietary information (vegan, gluten-free, lactose-free, allergies) for an in-person workshop, this falls under special category health data under GDPR Article 9.4. Legal Bases & How We Use Your Data
Under GDPR Article 6 (and Article 9 for special category data), 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 Deliver the 7-Day Accelerator Workshop: Processing registration, payment, dietary requirements, WhatsApp implementation group access, and post-event support for paid workshop attendees.
(Data used: Identity, Contact, Workshop Data, Phone Number if provided | Legal Basis: Contractual Obligation, with Explicit Consent for dietary restrictions under Article 9)* To Improve Service: Website analytics (GA4) via browser cookies.
(Data used: Technical Data | Legal Basis: Consent)* To Market: Retargeting ads (Meta Pixel) via browser cookies.
(Data used: Technical Data | Legal Basis: Consent)* To Measure Advertising Performance Server-Side: When you complete a purchase, we send a conversion event to Meta and Google from our server (not from your browser) so we can measure the performance of our advertising campaigns. This processing happens regardless of your cookie banner choice because it does not rely on cookies on your device.
(Data used: Hashed Identity and Contact Data, Purchase Data | Legal Basis: Legitimate Interest, balanced against your right to object. You can object by emailing us.)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: Hosting for smoney.lu and clarity.smoney.lu.
* Lovable (Supabase backend): Hosting and database for the Accelerator landing page and checkout at accelerator.smoney.lu.
* Stripe: Secure payment processing for paid workshops and mentorship (we do not store credit card details).
* MailerLite: Email marketing, newsletter delivery, and workshop confirmation emails.
* Make.com: Workflow automation between our payment system, email platform, and conversion tracking endpoints.
* Google Analytics (GA4): Anonymous website traffic analysis (browser-side, consent-based) and conversion measurement (server-side, legitimate interest).
* Meta (Facebook/Instagram): Ad performance tracking via the Meta Pixel (browser-side, consent-based) and the Meta Conversions API (server-side, legitimate interest).
* WhatsApp Business (Meta): Implementation group communications for paid Accelerator workshop attendees. Phone numbers and message content are processed by Meta.
* Notion: Internal client relationship management (CRM).
* Venue Partners (e.g., Novotel Luxembourg Centre): For in-person workshops, we share attendee headcount and any dietary restrictions you submit with the venue's catering team for the sole purpose of preparing your meal.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.
* Application Data: If you do not join a program, data is deleted after 12 months.
* Mentorship 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).
* Workshop Attendee Data: Identity, contact, and payment records are kept 10 years to satisfy Luxembourg accounting and tax obligations. Dietary restrictions are deleted within 30 days after the event. WhatsApp implementation group membership ends when the group is closed (typically 30 to 60 days after the workshop) or when you leave the group, whichever comes first.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.
* Right to Object: You can object to processing based on legitimate interest, including our server-side conversion tracking, by emailing us.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 two layers of tracking for analytics and advertising performance.Browser-Side Cookies (Consent-Based)* 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.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.Server-Side Conversion Tracking (Legitimate Interest)When you complete a purchase, we send a conversion event to Meta (via the Conversions API) and Google (via the Measurement Protocol) from our server. This is not browser-based and does not use cookies on your device, so it is not controlled by the cookie banner. The lawful basis is our legitimate interest in measuring the effectiveness of our advertising, balanced against your right to object. You can object to this processing by emailing us at the address above.9. Changes to This Policy
We may update this privacy policy to reflect changes in our practices or legal requirements.
Last Updated: 15 May 2026