[Last Modified: January 9, 2022]

This privacy notice (“Privacy Notice”) for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”) supplements the information contained in the Privacy Policy for Krembo LLC. dba Growth-X (collectively “Growth-X” or “Company” or “we” or “us” or “our “), and solely applies to our Customersand Website’s visitors who are residents of the State of California (as such is defined under the CCPA) (“Consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. Furthermore, this Privacy Notice is an integral part of our Privacy Policy and therefore, any defined terms that are used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.

The most recently amended date shall be reflected in the “Last Modified” title located at the bottom of this Privacy Notice.



Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer, household or device. The categories of Personal Information that we collect (and have collected within the last 12 months), are included in the table below.

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier,
Internet Protocol address, email address, account name, Social Security number,
driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute
(Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description,
address, telephone number, passport number, driver’s license or state identification
card number, insurance policy number, education, employment, employment history, bank
account number, credit card number, debit card number, or any other financial
information, medical information, or health insurance information.Some personal information included in this category may overlap with other
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion
or creed, marital status, medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression, pregnancy or childbirth and
related medical conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered,
or other purchasing or consuming histories or tendencies.
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying information,
such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,
gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a
website, application, or advertisement.
G. Geolocation data. Physical location or movements. Yes
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current or past job history or performance evaluations. No
J. Non-public education information (per the Family Educational Rights and Privacy Act
(20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational
institution or party acting on its behalf, such as grades, transcripts, class lists,
student schedules, student identification codes, student financial information, or
student disciplinary records.
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.



Depending on the nature of your interaction with us, we may collect the above listed information from you, as follows: (i) directly from you, for example, if you contact us or when you voluntarily provide us with your Personal Information; (ii) indirectly from you, for example, from observing your actions on our Website; or (iii) from third-party service providers such as analytical providers.



We may use, or disclose the Personal Information we collect from you for the business purposes included in our Privacy Policy, and as summarized below, as follows:

  • To set up your Customer Account;
  • To respond to your inquiries;
  • To send marketing communications;
  • For analytical purposes, among others, in order to enhance and develop our services;
  • For security and operational purposes;

We will not collect additional categories of Personal Information from you or use the Personal Information we collected for a materially different, unrelated, or incompatible purpose other than those we informed you of without providing you notice of such.



We may disclose your Personal Information to a third party, solely for a business purpose.

We share your Personal Information with the following categories of third parties:

Service Providers.


Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.


Sale of Personal Information:

The Company has not sold Personal Information in the last twelve (12) months.


Your Rights Regarding Your Personal Information

Please review our User Rights Policy. for more information regarding the rights you may have under the relevant data protection and privacy laws in your jurisdiction. You may exercise any or all of your above rights in relation to your Personal Information by filling out our Data Subject Request form and emailing it to us at: dpo@growth-x.com. Once we receive a request from you, we may ask you to provide us with more information or documentation in order to verify your request. We aim to respond to your verified request without undue delay and in any event according to the time frame set forth under applicable laws. If we require more time to respond to your request, we will inform you of the reasoning behind the extension period and the duration of such period in writing. Our response will also explain the reasons why we are unable to comply with a request, if applicable.



If you have any questions or comments about this Policy, or any concerns with respect to how your privacy any information are handled, please contact us at:

Krembo, LLC.

3650 NW 82 avenue suite 401, Doral, FL 33166

You can also contact us via email at: dpo@growth-x.com