Terms of Use as of October 1st, 2025
goandgrow.eu Privacy Policy as of January 10th, 2026
This Privacy Policy provides an overview of what personal data of the goandgrow.eu Portal User (hereinafter also You) the company (hereinafter Go & Grow or us) processes when providing services via the Portal, how and for which purposes it does this, and what Your rights are regarding Your personal data. As personal data means any information relating to an identified or identifiable natural person, this Privacy Policy applies exclusively to Users who are natural persons and not to Users who are legal entities.
We follow very strict rules established for the processing of Your personal data, which derive from the European Union and Estonian legislation on the protection of personal data, including the European Union General Data Protection Regulation (hereinafter General Regulation). The terms contained in this Privacy Policy have the same meaning as described in the goandgrow.eu Terms of Use and General Regulation.
Controller and Contact Details
The controller of Your personal data is Go&Grow OÜ (Estonian registry code 12831506; postal address Sõjakooli tn 6, Kristiine, Tallinn, Harju maakond, 11316, Estonia). You can find the form required to contact us here.
Collection of Personal Data
We generally collect personal data necessary to enter into an Agreement with You and perform it. Given our field of activity, it also includes collecting various background information to fulfill our various statutory obligations.
We collect personal data from the following sources:
- Yourself (e.g., data submitted and shared by You); and
- Third parties (e.g., public sources (media), sanctions lists, cooperation partners (for identification purposes), and companies belonging to the same group as us).
We collect personal data from third parties that allow us to apply due diligence measures to prevent money laundering and terrorism financing.
We may also collect personal data automatically (e.g., the way You use the Platform, digital devices You use, and cookies) for statistical purposes.
Use of Your Personal Data
To provide services to You through the Platform, You may be required to provide our partners or us with the information necessary to provide the services. If You do not provide this information, we are not able to provide services to You. Such information is always marked accordingly.
We use Your personal data for the following purposes and on the following legal bases:
We may also process Your personal data for other purposes with Your consent. The purpose of the processing and other details, in this case, are described in the consent.
If the legal basis for the processing of Your personal data is our or a third party's legitimate interest, You have the right to obtain additional information and to object to such processing at any time. To do so, please contact us using the contact details mentioned above.
Transfer of Personal Data
When we process Your personal data, we also transfer Your personal data to our processors or third parties. Such transmission shall take place only under the following conditions:
Processors. We use carefully selected service providers (processors) to process Your personal data. In doing so, we remain fully responsible for processing Your personal data.
We use the following processors: marketing and survey service providers and tools, money laundering and terrorism financing risk mitigation searching service providers, identification service providers, customer support service providers, accounting service providers, server management and server hosting providers, IT service providers, and other companies belonging to the same group as us, who provide services to us.
If You would like more detailed information about our processors (e.g., their names and locations), please contact us using the contact details mentioned above.
Third Parties. We will only share Your personal data with third parties if set out in this Privacy Policy if required by applicable law (e.g., if we are required to share personal data with authorities) or under Your consent or order.
We may share Your personal data with the following third parties:
- to make transactions selected by You via the Portal, with other Users. In this case, the legal basis for the transfer of personal data is the conclusion or performance of the Agreement (point (b) of Article 6(1) of General Regulation);
- to perform the Agreement, with payment service providers. In this case, the legal basis for the transfer of personal data is the performance of the Agreement between us (point (b) of Article 6(1) of General Regulation);
- for the purposes of our internal administration, with companies belonging to the same group as us. In this case, the legal basis for the transfer of personal data is our legitimate interest in sharing the data with companies belonging to the same group as us for internal administration purposes (point (f) of Article 6(1) of General Regulation);
- for the purposes of direct marketing, with companies belonging to the same group as us. In this case, the legal basis for the transfer of personal data is Your consent (point (a) of Article 6(1) of General Regulation);
- to fulfill our statutory obligations, with authorities and law enforcement agencies. In this case, the legal basis for the transfer of personal data is fulfilling our statutory obligations (point (c) of Article 6(1) of General Regulation);
- to protect our rights and interests, with collection agencies, attorneys, bailiffs, and other persons concerned. In this case, the legal basis for the transfer of personal data is our legitimate interest in protecting our rights and interests (point (f) of Article 6(1) of General Regulation). We will only transfer Your personal data if we are sure that our legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected. As we generally transfer Your personal data only when it is essential to protect our rights and interests (i.e., if there has been a breach or a suspected breach by You), we consider it justified.
- to fulfill our statutory obligations, with auditors. In this case, the legal basis for the transfer of personal data is fulfillment of our statutory obligations (point (c) of Article 6(1) of General Regulation and the Auditors Activities Act);
- to fulfill our statutory obligations or in the legitimate interests of us or our counterparty, if such transfer is necessary to transfer our activities or assets due to a transaction, or to assess the potential of such a transaction. In this case, the legal basis for the transfer of personal data is the fulfillment of our statutory obligations (point (c) of Article 6(1) of General Regulation and the Law of Obligations Act), or the legitimate interest of us or our counterparty in concluding the transaction or assessing its potential (point (f) of Article 6(1) of General Regulation). We will only transfer Your personal data if we are sure that our or our counterparty’s legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected.
If the legal basis for the processing of Your personal data is our or a third party's legitimate interest, You have the right to obtain additional information and to object to such processing at any time. To do so, please contact us using the contact details mentioned above.
Transfer of Personal Data outside the European Union
In general, we do not transfer Your personal data outside the European Union, but our processors and third parties to whom we transfer the personal data may process Your personal data outside the European Union. Where necessary, the transfer will only take place if we have a legal basis for such action, including, in particular, if the recipient: (i) is located in a country that the European Commission considers having an adequate level of protection of personal data, or (ii) is acting under an agreement that meets the requirements of the European Union for the transfer of personal data to processors outside the European Union.
If You would like more detailed information about the transfer of Your personal data outside the European Union (e.g., the recipients' names and the legal basis for the transfer), please contact us using the contact details mentioned above.
Retention of Personal Data
We retain Your personal data for as long as we are required by law to do so (e.g., under the Accounting Act we must retain accounting source documents for seven years from the end of the respective financial year) or until we have a legitimate interest in doing so (e.g., until the end of the limitation period of claims to protect our interests and rights if necessary).
Security of Personal Data
We ensure that Users' personal data is only available to such employees who, due to their duties, need to have access to such data. All Go & Grow employees are required to maintain the confidentiality of the data and may not share the information with third parties, except for the purposes set forth above.
Personal data is stored and archived on a secure server that only a few people have access to. Security is guaranteed by strict privacy standards met by conscientious third-party partners.
We use several Internet security measures to ensure the secure processing, transmission, and archiving of personal data.
The servers are located in a data center in Frankfurt, Germany, and are operated by Telehouse, one of the world's 200 leading companies. A separate agreement has been concluded with Virtion GmbH for server management. These companies allow us to offer better availability and growth potential of our IT resources and greater flexibility.
All their activities comply with a number of standards, including ISO 27001 (Information security management) and ISO 22301 (Business Continuity Management System Certificate) standards.
In Go & Grow, security breaches are detected, monitored, and repelled by software and hardware security walls.
Your Rights
You have all the rights of the data subject with regard to Your personal data to the extent required by the applicable data protection legislation, including:
- the right to receive relevant information on the processing of personal data;
- the right to receive a confirmation of whether personal data is being processed;
- the right to receive a copy of personal data;
- the right to request that we rectify inaccurate personal data or supplement incomplete personal data;
- the right to request deletion of personal data if: (i) the personal data is no longer necessary for the purpose for which it was collected or otherwise processed; (ii) You withdraw Your consent for processing Your personal data, and there is no other legal basis for processing the personal data; (iii) You object to the processing of personal data, and there are no overriding legitimate reasons for the processing; (iv) You object to the processing of Your personal data for direct marketing purposes; (v) personal data has been processed unlawfully; or (vi) personal data must be deleted to fulfill our statutory obligation. Notwithstanding the above, You do not have the right to request the deletion of personal data if the processing is necessary: (a) for the fulfillment of our statutory obligation; or (b) for the establishment, exercise or defense of legal claims;
- the right to request a restriction on the processing of personal data if: (i) You challenge the accuracy of the personal data for a period of time that allows us to verify the accuracy of the personal data; (ii) the processing of personal data is unlawful, whereas You do not request the deletion of personal data, but the restriction of use; (iii) we no longer need personal data for processing purposes, but the data is necessary for You for the establishment, exercise or defense of legal claims; or (iv) You have objected to the processing of Your personal data, while we check whether our legitimate reasons outweigh Your reasons. If the processing of personal data is restricted, we may nevertheless process it: (a) with Your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest;
- the right to portability of data, i.e., the right to receive personal data that You have provided to us in a structured, commonly used and machine-readable format, and the right to transmit this data to another controller if: (i) the processing is with Your consent or for the purposes of conclusion or performance of the Agreement; and (ii) processed automatically. If technically feasible, You have the right to request that we transmit the data directly to another controller. In exercising Your right, we cannot infringe on the rights and freedoms of others;
- the right to object, depending on Your particular situation, at any time to the processing of personal data in the legitimate interest of us or a third party. In this case, we will not further process personal data unless we prove that the processing is for a valid legitimate reason that outweighs Your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims. If Your objection concerns the processing of Your personal data for the purposes of direct marketing, we do not have the right to process Your personal data further;
- the right to withdraw consent at any time. To do so, You may contact us using the contact details mentioned above or use other options described in obtaining Your consent.
To exercise Your rights, please contact us using the contact details mentioned above. We will respond to Your request within one month at the latest. In some instances (taking into account the complexity and number of the requests), we have the right to extend the due date for replying by two months. In this case, we will notify You.
If You believe that Your rights have been violated, please contact us immediately to resolve the situation. However, You have the right to complain to the Member State’s supervisory authority where You have Your permanent residence or place of work, or to the Data Protection Inspectorate (www.aki.ee; info@aki.ee; Tatari 39, 10134 Tallinn, Estonia).
Links to Third-Party Websites
Links to third-party websites from the Platform or any other Go & Grow website, or vice versa, are only quick links to services or topics useful to our Platform Users. Please note that third-party websites may have different privacy policies and/or security standards, which we recommend You review.
Amendments to the Privacy Policy
Suppose our personal data processing practices are changed, or we need to amend this Privacy Policy due to applicable law, judicial or competent supervisory authorities' practices, or competent supervisory authorities' guidelines, we have the right to change this Privacy Policy at any time unilaterally. In this case, we will notify You via the Portal or email at a reasonable time before the changes take effect.
Applicable Law
As Go & Grow is a company registered in the Republic of Estonia, Estonian law applies to the processing of Your personal data.
This Privacy Policy was last updated as at May 19, 2025.
What is a Cookie?
A cookie is a small morsel of text that a website asks your browser to store. All cookies have expiration dates in them that determine how long they stay in your browser. Cookies can be removed in two ways: automatically, when they expire, or when you manually delete them. We've included more details below to help you understand what kinds of cookies we use.
Please remember that by deleting existing cookies or disabling future cookies you may not be able to access certain areas or features of our website.
What Cookies Does the Company Use?
We use cookies across our website to improve the performance and enhance the user experience. Please be advised that when you visit our website you agree that we use the following cookies:
Essential cookies that are only set or retrieved by the website while you are visiting which allow us to identify you as a subscriber and ensure that you can access the subscription only pages. We can ensure that no one is making changes to your profile, acquiring or selling the Claims on your behalf.
Functionality cookies are used to allow us to remember your preferences on the website, such as language or username to customize your user experience.
Performance cookies allow us to collect information how you use the website. All of the information collected is anonymous and is only used to help us improve the way our website works and measure the effectiveness of our advertising campaigns.
Third party cookies are behaviourally targeted advertising cookies (e.g. Google Analytics) that allow us to record pages that are visited and the links that are followed. The information collected in non-identified.
Secure cookies are used to ensure that any data in the cookie will be encrypted as it passes between the website and the browser. It helps us to protect the security of your account.
How to Change Cookies' Settings?
In case you want to change your preferences about the cookies that we use, please change your browser settings. For more information you may wish to visit http://www.aboutcookies.org/
Procedure for processing complaints
We want you to be happy with the services Go & Grow provides. However, if this is not the case and you are dissatisfied with the service requested by or provided to you, or its terms and conditions or quality, we want to know about it. In order to process your complaint as quickly and efficiently as possible, please read this procedure before filing a complaint.
How do I file a complaint?
Go & Grow’s customer support is fully digital. This means we can handle and solve complaints quickly and securely online. You can file a complaint via the feedback form on our FAQ page.
What information should I include in the complaint?
Please provide all the relevant information so we can review your complaint as quickly and efficiently as possible. Describe and specify the problem as clearly as you can. Also state the claim or request that you want Go & Grow to solve.
Please include any relevant documents in your complaint if they are not easily available to Go & Grow.
If your representative is filing a complaint on your behalf, please attach a document that proves their rights of representation. This can be a power of attorney letter, or another relevant document(s).
How will Go & Grow process the complaint?
Go & Grow treats all customers with respect and without prejudice. We will determine the specific circumstances regarding your complaint and determine the root cause of the problem. If necessary, we may ask you for additional information or documents to help our process.
If the complaint is valid, we will immediately do what we can to fix the problem or offer another solution. If, however, we do not agree with your complaint (either partially or entirely), we will explain our reasons when we reply to you.
When can I expect a reply?
Once we receive your complaint, you will receive an automated email notification (Usually within one business day).
Normally, we settle complaints within five business days after receiving it, but it may take up to 15 days. If we can't settle your complaint within 15 days, we will inform you why it's taking longer and set a new date for when you can expect a reply.
What should I do if I’m not happy with the solution you provided?
We will do our best to give a solution that you are happy with. However, if you are unhappy with our suggestion, answers, or explanations, you can appeal the decision by contacting us again.
If you are still dissatisfied with the solution we offered, you are entitled to turn to following authorities to protect your rights:
- Consumer Protection and Technical Regulatory Authority (complaints related to the User Agreement, https://www.ttja.ee/en; located at: Endla 10a, 10142 Tallinn, Estonia; email: info@ttja.ee; phone: 620 1707);
- Court (according to the jurisdiction specified in the User Agreement or other agreements concluded with Go & Grow);
- Consumer Complaint Committee (complaints related to the User Agreement, www.komisjon.ee; located at Endla 10a, 10142 Tallinn, Estonia; email: avaldus@komisjon.ee; phone: 620 1707). Since the User Agreement is concluded via electronic means, it is also possible to seek an out-of-court settlement by submitting the complaint online via the ODR platform at ec.europa.eu/odr;
- Data Protection Inspectorate (personal data related complaints, www.aki.ee; located at Tatari 39, 10134 Tallinn, Estonia; email info@aki.ee; phone: 627 4135).
Conflicts Policy
Introduction
Any conflicts of interest, which may arise in relation to the Company, shall be identified and managed by the Company. We will maintain and manage all arrangements necessary to prevent a conflict from escalating to causing material damage to the interests of our Users. The given document states our conflicts of interest policy (herein further referred to as "Conflicts Policy") in as much as it applies to our activities.
We are fully committed to complying with our regulatory and legal obligations and maintaining ethical standards. We require that all of our employees are contractually bound to comply with our Conflicts Policy, and any breach of such may lead to disciplinary proceedings, not excluding discharge of services.
Potential or Actual Conflicts Indication
A conflict of interest may take place if any of the Company directors, employees, outsource partners or otherwise "relevant persons" linked to the Company by control is providing a service to the Users or engaging in activities on their own account, which may cause a material risk or damage to the Users; interests, for example where any of the mentioned above-mentioned persons:
- could either make a financial gain or avoid a financial loss, on account of a User;
- has an interest in the outcome of a rendered service, which is different from the interest of a User;
- is incentivized to offer the privilege to one of the Company’s clients on account of another User;
- receives an incentive in any form (financial/goods/services) other than the standard commission fee, from a person other than the User, for a service rendered to a User.
Employees
A conflict of interest may occur if the Company's employee (or the employee's family) is somehow associated with the other party of any given transaction, especially if such a party is a User. This association may include being a director, a significant shareholder or a consultant to any User. The Company's employees are required to disclose any connection, which could compromise their judgment, or involve any material interests.
Managing Conflicts of Interest and Disclosure
The Company will take all possible and reasonable efforts to mediate any conflict of interest.
Should there be a considerable risk of damage to any User, we will issue an appropriate disclosure.
We will carry out all necessary procedures, including employee training, to ensure that circumstances at which conflict of interest may arise are identified and properly managed.
All conflicts, which may arise, shall be closely monitored.
Further Information
The given document shall be reviewed and updated, as necessary. In case of any questions in regards to this policy, please contact us via the Portal.
Capitalized terms bear the meaning outlined in the Terms of Use, unless defined otherwise.