Privacy Policy & SMS Terms

Last updated: 8 October 2026

This policy explains how we collect and use personal data through clientgrowthsystems.com, and what rights you have over it. Our text messaging programme terms are part of it, in Mobile messaging below.

Who we are

The controller of your personal data is Dawid Kurpiel, trading as Client Growth Systems, Raba Wyżna 400, 34-721 Raba Wyżna, Poland, NIP 7352896269, REGON 388652650, registered in CEIDG (“we”, “us”). For anything relating to privacy, contact us at support@clientgrowthsystems.com.

We are not required to appoint a Data Protection Officer and have not appointed one. Privacy enquiries go to the address above and are handled by us directly.

What we collect

Details you give us. When you submit the contact form or get in touch: your first name and your phone number, email address, or both, plus anything else you choose to tell us. On our short questionnaire for contractors, also your business name and your answers: your trade, roughly how many calls you miss a week, your biggest problem right now, and your monthly revenue band.
Consent records. If you tick the box agreeing to texts, we keep a record of that consent, its exact wording, and when it was given. We need this to show the consent was valid.
Call and message records. The fact that a call or message happened, when, and any notes we make about it. Where a call is recorded, the recording itself — see Calls and call recording below.
Technical data. Information your browser sends automatically, such as IP address, device and browser type, and the pages you visited. Our host generates this as part of serving the site.

We do not ask for, and ask that you do not send us, sensitive information such as payment card numbers or government identifiers through the contact form.

Giving us your details is voluntary. You are not under any statutory or contractual obligation to provide them. If you choose not to, we simply will not be able to answer your enquiry or arrange a call — there is no other consequence.

Why we use it, and our lawful basis

To answer your enquiry and arrange a call. Our legitimate interest in responding to people who contact us, or the steps taken at your request before entering a contract.
To call and text you about our services. Your consent, given by ticking the box on the form. You can withdraw it at any time.
To provide our services to clients. Performance of our contract with you.
To measure and target our Meta ads, for visitors in the United States. Our legitimate interest in advertising our services to the market we serve. You can opt out at any time under Your privacy choices.
To keep the site secure and working. Our legitimate interest in running a functioning, secure website.
To meet legal and tax obligations. Compliance with a legal obligation.

Mobile messaging

This section is the full terms of our text messaging programme. It is part of this policy rather than a separate document, so the sections above and below — on what we collect, who we share it with and how long we keep it — apply to your mobile number too.

The programme

The programme is called Client Growth Systems Alerts. It is run by us, the controller named under Who we are, and messages are sent from our toll-free number. To take part you must be at least 18 and either the account holder for the mobile number you give us or have the account holder’s permission to use it. We message mobile numbers in the United States.

What we send

Where you have agreed to it, we may text you to:

reply to an enquiry you sent us;
confirm, reschedule or remind you about a call;
follow up on a quote or a conversation already under way;
tell you about our services, offers and updates, where you have agreed to marketing messages.

Typical messages look like this:

“Client Growth Systems: thanks for getting in touch. Is 2pm tomorrow still good for your call? Reply STOP to opt out.”
“Client Growth Systems: just checking you got the quote we sent over. Any questions, reply here. Reply STOP to opt out.”

How you opt in

You opt in by giving us your mobile number and ticking the consent box on the contact form at clientgrowthsystems.com, or by asking us in writing or during a call to text you. The box is never ticked for you, and submitting the form without it does not opt you in. By opting in you agree to receive text messages from us at that number, including messages sent using automated technology. Consent to receive marketing messages is not a condition of buying anything from us, and you can withdraw it at any time. The record we keep of that consent is described under What we collect.

Frequency and cost

Message frequency varies and depends on how you interact with us. We do not send on a fixed schedule, and we will not send more than 8 messages per month. We do not charge for these messages, but message and data rates may apply depending on your mobile plan and carrier.

How to stop

Reply STOP, END, CANCEL, UNSUBSCRIBE or QUIT to any message to opt out. We will send one confirmation and then stop, other than messages you specifically ask for afterwards. Reply HELP or INFO and we will text back the name of the programme, Client Growth Systems Alerts, and how to reach us. If you change your mind, reply START or UNSTOP to join again.

You can also use any of the contact routes at the end of this policy to opt out, or to tell us your mobile number has changed so we do not message whoever takes it over next. Opting out puts your number on a do-not-contact list, which we keep for as long as How long we keep it describes.

Delivery

Mobile carriers are not liable for delayed or undelivered messages. We cannot guarantee that every message will arrive, and delivery depends on your carrier and your device.

Your number is never shared

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All of the other categories of data described in this policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. Your number is used only by us and by the messaging providers listed under Who we share it with, who deliver messages on our behalf and cannot use it for anything else.

Email messages

We email you to reply to your enquiry, and — where you have agreed to it — about our services, offers and updates. Every marketing email carries an unsubscribe link and our postal address. You can unsubscribe using that link, or by emailing support@clientgrowthsystems.com, and we will stop within ten business days. We will still send you messages you have specifically asked for, and messages about work already under way.

Calls and call recording

If you give us your phone number and agree to be contacted, we may call you about your enquiry and about our services.

We do not record calls by default. If we ever do record one, we will tell you at the start of that call and you can ask us not to, or end the call, without any consequence. We rely on your consent to record. Recordings are kept for up to 12 months and then deleted, unless we need one longer to deal with a dispute or a legal claim.

When we handle data for our clients

Everything above describes us as the controller of data about our own enquirers and clients.

When we build and run a website, CRM or follow-up system for a client, we also handle personal data about that client’s own customers. For that data we act as a processor: we handle it only on the client’s documented instructions, under a written data processing agreement, and the client’s own privacy policy governs it. If you are a customer of one of our clients and want to exercise your rights, contact that business. If you contact us instead, we will pass your request on to them.

Cookies and tracking

Apart from the Meta measurement described below, which runs only for visitors in the United States, the site sets no cookies beyond what is strictly necessary to serve and secure the pages and to remember an opt-out, plus one note in your browser’s storage that you finished the questionnaire, so it isn’t asked again; and the fonts it uses are served from our own domain rather than from a third party.

We use Cloudflare Web Analytics to count visits and see which pages people read and which sites they arrive from. It is cookieless and aggregated: it sets no cookie, stores nothing on your device, does not follow you to other websites and does not build a profile of you. It does not fingerprint visitors from their IP address or browser, so your visits cannot be linked back to you or joined up over time. Because it needs no non-essential cookie, it runs without a consent banner.

We also keep our own summary of each visit in Airtable. It records the page you landed on, the time, the site or campaign tags (such as utm_source) that brought you here, your approximate location at country and city level, and your device type and whether you opened the site in an in-app browser. It also records how long you spent on the site, how far down the page you scrolled, which sections you reached and in what order, which of the buttons that lead to the contact form you clicked, and how far you got with the form. For the form we note only which boxes you filled in and which one you were in last, never what you typed. On the questionnaire page we also note how far you got through the questions, where you closed it, and the multiple-choice answers you picked, but none of your contact details. If you came from one of our Facebook or Instagram ads, we note that and the name of the ad, but not Meta’s click identifier.

The summary records no name, no IP address and sets no cookie. A visit’s entries are grouped under a random number that exists only while the page is open: it is not stored on your device and is gone when you close the tab, so a return visit starts a new, unconnected summary. We use it to see which pages and which advertising work.

If you visit from the United States, we also measure our Meta (Facebook and Instagram) ads. Through Cloudflare Zaraz, which sends the data from Cloudflare’s servers rather than loading Meta’s code in your browser, we tell Meta that a visit happened, whether you reached and started the contact form, whether you spent some time on the site, and whether you sent the form. Meta receives these with a cookie identifier, the ad click identifier if you came from an ad, and your IP address and browser details, which it uses to match the visit to the ad you saw. It never receives your name, phone number, email address, business name or questionnaire answers. Meta uses this to measure our ads, to show them to people more likely to be interested, and to build audiences for our ads. Visitors from outside the United States are not measured this way at all. You can opt out at any time under Your privacy choices, and a Global Privacy Control signal from your browser opts you out automatically. Our own Airtable summary records only whether the visit was measured.

Your privacy choices

This switch stops our Meta ad measurement in this browser, for a year or until you switch it back. It works by setting one small cookie that says so, so clearing your cookies switches it back on.

We do not sell your personal data. We share it only with providers who process it on our behalf, under contract:

Cloudflare — website hosting, delivery and security, the cookieless visitor analytics described above, and the Meta ad measurement (Cloudflare Zaraz).
Meta Platforms Ireland — ad measurement and audiences, for visitors in the United States who have not opted out, as described above. Meta is not our processor but a joint controller for this collection, and uses the data under its own privacy policy as well.
Airtable — storage for the anonymous visit summaries described above.
Our email provider — to receive and reply to your messages.
GoHighLevel — CRM, calling and messaging, once it is in use for enquiries.

We may also disclose data to professional advisers, or to authorities where the law requires it.

International transfers

We are based in Poland, and some of our providers are based in the United States. Where personal data is transferred outside the European Economic Area, that transfer relies on an adequacy decision, the EU Standard Contractual Clauses, or another safeguard permitted under Chapter V of the GDPR. You can ask us for a copy of the safeguard that applies to a particular transfer.

How long we keep it

Enquiries that do not become clients: up to 24 months from your last contact with us, then deleted.
Client records: for the length of the engagement, then as long as needed for legal and tax purposes.
Consent and opt-out records: kept as long as needed to prove consent and to honour opt-outs. An opt-out record is kept indefinitely so we do not contact you again by mistake.
Call recordings: up to 12 months, unless needed longer for a dispute or legal claim.
Server and security logs: up to 12 months.
Accounting records: five years from the end of the tax year, as required by Polish law.

Automated decisions and profiling

We do not make decisions about you by automated means alone, and we do not profile you in any way that produces legal effects or similarly significantly affects you. Our follow-up messages are scheduled automatically, but a person decides whether and how we work with you.

Your rights

Under the GDPR you have the right to:

access a copy of the personal data we hold about you;
have inaccurate data corrected;
have your data erased;
restrict how we process it;
receive it in a portable format;
object to processing based on our legitimate interests, including direct marketing;
withdraw consent at any time, without affecting processing already carried out.

To exercise any of these, email support@clientgrowthsystems.com. We will respond within one month. If you think we have handled your data wrongly, you can complain to the Prezes Urzędu Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warsaw, Poland, or to the supervisory authority in the EU country where you live or work.

If you are in the United States

Depending on your state, you may have the right to know what personal information we have collected, to have it deleted or corrected, to receive a copy, and to opt out of its sale or sharing. We do not sell personal information. We do share it for cross-context behavioural advertising, in one way only: the Meta ad measurement described under Cookies and tracking, which shares identifiers (a cookie identifier, the ad click identifier and your IP address) and internet activity (the pages and form steps you reached) with Meta. You can opt out of it under Your privacy choices. We do not use or disclose sensitive personal information beyond what is needed to provide the services you asked for. We will not discriminate against you for exercising these rights.

In the last 12 months we have collected these categories of personal information, in each case directly from you or automatically from your device. We disclosed them for a business purpose only to the service providers listed above, and shared the identifiers and internet activity with Meta as described above, unless you opted out:

Identifiers — name, business name, email address, phone number, IP address, cookie and ad click identifiers.
Commercial information — the services you enquired about and our correspondence with you.
Internet or network activity — pages viewed, browser and device type.
Professional information — your trade and the business you run.
Audio information — a call recording, in the limited circumstances described above.

To make a request, email support@clientgrowthsystems.com. We will ask you to confirm details we already hold so we can verify that the request is really yours, and we will respond within 45 days, extendable once by a further 45 days if we tell you why. An authorised agent may make a request on your behalf if they give us written permission signed by you, and we may still ask you to verify your own identity. If we refuse a request we will tell you why, and you can ask us to reconsider by replying to that response.

We honour Global Privacy Control. If your browser sends it, we treat it as an opt-out of the Meta sharing above, automatically and without you having to do anything else.

Security

The site is served over HTTPS and we restrict access to enquiry data to those who need it. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Children

This site is aimed at business owners and is not directed at children. We do not knowingly collect personal data from anyone under 16. If you believe we have, contact us and we will delete it.

Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed. If a change is significant we will make that clear on this page.

Contact

Dawid Kurpiel
trading as Client Growth Systems
Raba Wyżna 400, 34-721 Raba Wyżna, Poland
NIP 7352896269 · REGON 388652650
support@clientgrowthsystems.com