Privacy notice

Firo Growth LLC (Firo, we) is the controller of the personal data described in this notice. Our postal address is 30 N Gould St # 4673,30 N Gould St # 4673, Sheridan, WY 82801-6317, United States.82801-6317, United States. You can reach us about privacy at info@firogrowth.com.

This notice covers the website firogrowth.com, our calendar at cal.firogrowth.com, the checkout, the kickoff preparation form, and contact with us by email or WhatsApp. Our site and services are for businesses.are for businesses.

If your details are in a prospect list that Firo built for one of its clients, that client decides how they are used. Write to us, and we pass your request on to the client and remove you from our own working files.own working files.

When you visit the site, our servers receive the technical details needed to show the pages and keep the site secure. These are your IP address, the time, the pages requested, and basic browser and device details. We keep them in security logs. We do not use them to build a profile of you.

The site runs no advertising scripts, and we do not work out which company a visitor comes from. We count visits with a privacy-friendly counter we host ourselves. It sets no cookies and does not store your IP address. It notes the pages you view, the site you came from, your approximate location and the kind of device.

You can book a call through our calendar at cal.firogrowth.com. The calendar software runs on our own server. When you book, we receive your name, email address, time zone, the time you picked and what you write in the booking form. The booking is added to our Google calendar, and the call takes place on Google Meet.

When you email us, we receive your email address and what you write. When you choose to message us on WhatsApp, we receive your phone number, your profile name and your messages. WhatsApp is a service of Meta, which handles your messages under its own terms and privacy policy.

In the checkout you enter your name, work email, company, website, role and billing country. Where we ask for them, you also give your billing address and your VAT number, and in the United States your state and ZIP code. You choose your add-ons, your list options and a kickoff time.

We receive these details when you press “Continue to kickoff”. There is one thing that reaches us earlier. If you fill in a VAT number, we receive your details as soon as you leave that field, because we check the number for you while you are still ordering.

If you give a VAT number from the European Union, we send that number, its country and your company name to the VIES service of the European Commission, which tells us whether the number is valid. We keep its answer with your order, because it supports the way VAT is treated on your invoice.

When you place an order, we record the order and the payment method you chose. We record the version of the service terms you accepted, with the date and time. Your first order email links to that version and names it.

We make an invoice with your company and billing details and email it to you when you place the order. We also record your kickoff booking. The booking is made in our own calendar at cal.firogrowth.com and added to our Google calendar, and the call takes place on Google Meet.

The order itself is governed by the Pipeline System Setup service terms. They also set out how Firo handles prospect data and other personal data it works with for a client.

When the checkout offers you a card, iDEAL, also called Wero, or ACH payment, Stripe handles it. You enter your payment details with Stripe directly. We never receive your full card number or your bank sign-in details. Stripe tells us whether the payment succeeded and gives us basic details, such as the card type, the last four digits and the country. Stripe also uses payment data to prevent fraud, as a controller under its own privacy policy.

With a bank transfer you pay into our company account at Airwallex. In the checkout you confirm that you made the transfer. When the money arrives, we see the payer’s name, the account it came from, the amount and the payment reference.

Before the kickoff we ask you to fill in a preparation form. It has its own page, which you open with the link in your order email. Your answers are saved on our server while you type, so that you can stop and come back, also on another device.

Your answers can name other companies and people, such as your best clients, the people in your team and their LinkedIn profiles. We handle those details for you as your processor, under the data processing terms at the end of the service terms.

We record each time the form is opened, with the time. We may also note the country, the region and the kind of device you used, worked out from your connection. We do not store your IP address or the identification your browser sends.

We delete the answers 180 days after your kickoff. We keep the record of when the form was opened, saved and submitted.

We send the emails about your order through ZeptoMail, an email sending service of Zoho. These are the order confirmation, the invoice, the kickoff invitation, the link to the preparation form, and messages about your payment or kickoff. ZeptoMail tells us whether an email was delivered or bounced. Our emails do not report back whether you opened them or clicked a link in them.

We use your details only for the purposes below. For visitors in the European Union and the United Kingdom, each purpose names its legal basis under the General Data Protection Regulation (GDPR).

• To take and carry out your order, and to take the steps you ask for before it. This covers booking a call, saving your checkout details, holding a kickoff time, checking a VAT number, taking payment, sending order emails and delivering the service. The legal basis is the contract, article 6(1)(b).the contract, article 6(1)(b).
• To run and secure the site, prevent fraud and misuse, answer business enquiries, see which checkouts were left unfinished and get in touch once about them, and defend legal claims. The legal basis is our legitimate interests in a secure business site and in following up on orders that were started, article 6(1)(f). You can object at any time.at any time.
• To keep the order, invoice and payment records that tax and accounting rules require. The legal basis is a legal obligation, article 6(1)(c), and otherwise our legitimate interest in proper business records, article 6(1)(f).

The details marked as required in the checkout are needed for an order. Without them we cannot take it. We do not sell the personal data described in this notice, and we make no decisions about you by automated means alone.

If you start the checkout and we receive your details but you do not place the order, we keep what you filled in for thirty days. That is your name, work email, company, website, role and billing country, what you selected, and the kickoff time we held for you if you picked one.

We see that the checkout was left unfinished. You get no automatic email from us. We may get in touch with your business once about it, for example to ask whether you have a question. That one message carries no offer.

After thirty days we delete these details. You can ask us at any time to delete them sooner or not to contact you.to contact you.

We share personal data only with the providers we need to run the site and deliver the service, and only as far as each one needs it.

• Our hosting provider, for the website, the order system and the calendar. Those servers are in Singapore. Our own internal systems run on servers in France.
• Stripe (United States), when you pay by card, iDEAL or ACH.
• Airwallex (Netherlands) B.V. for our euro account and Community Federal Savings Bank (United States) for our US dollar account, where bank transfers arrive.bank transfers arrive.
• ZeptoMail by Zoho (United States), for sending order emails.sending order emails.
• Google (United States), for our email, calendar and video calls.
• The VIES service of the European Commission, when we check a VAT number from the European Union.the European Union.
• Meta (United States and Ireland), only when you choose to contact us on WhatsApp.
• The platform that hosts the client portal, once you are a client.
• Authorities and courts, only where the law requires it.law requires it.

We do not sell or rent the personal data described in this notice, and we do not share it for advertising.

Firo is a United States company. Our team and most of our providers work outside the European Union and the United Kingdom. Your details are therefore handled in the United States and in other countries, including Singapore.countries, including Singapore.

Some personal data from the EU or the UK goes to providers in countries without an adequacy decision. Where a provider is certified under the Data Privacy Framework between the EU and the United States, we rely on that framework. Otherwise we rely on the standard contractual clauses of the European Commission, with the UK addendum where needed. You can ask us for a copy of the safeguards that apply.safeguards that apply.

• We keep orders, invoices and payment records for seven years.for seven years.
• We delete an unfinished checkout after thirty days.after thirty days.
• We blank the text of an email we sent after thirty days. We keep the record that we sent a message of that kind, and when.
• We delete your kickoff preparation answers 180 days after your kickoff. We keep the record of when the form was opened, saved and submitted.
• We keep enquiries by email or WhatsApp, and booked calls that did not lead to an order, for two years after the last contact.
• We keep other client material for two years after our last contact, unless you ask us to delete it sooner. Personal data about other people in that material is handled under the data processing terms at the end of the service terms.
• We keep security logs for at most ninety days.

After these periods we delete the data or make it anonymous. We keep data longer only when a law requires it or when we need it for a legal claim.

If the GDPR applies to you, you can ask us for access to your data, for correction, for deletion, for restriction of its use, and for a copy you can take to another provider. You can object to uses based on our legitimate interests, including being contacted about an unfinished checkout.

To use a right, email info@firogrowth.com. We answer within one month and may ask you to confirm who you are. It costs nothing. Wherever you live, you can ask us what we hold about you and ask us to correct or delete it.

If you think we handle your data wrongly, please tell us first so that we can put it right. You also have the right to complain to a supervisory authority. In the EU this is the data protection authority of the country where you live or work. In the United Kingdom it is the Information Commissioner’s Office.

The site stores only what it needs to work. This is everything it stores on your device.

• firo-consent-v1 in local storage. It remembers that you closed the cookie notice, so that the notice is not shown again. It stays until you clear your browser storage.
• firo-checkout-list-signals in session storage. It remembers the list options you chose in the checkout, for that browser tab only. It is removed when you close the tab.
• A secure, HttpOnly cookie named __Host-firo_checkout, set when you start an order. It lets you come back to a saved order and expires after thirty days.
• A secure, HttpOnly cookie named __Host-firo_checkout_lead, set when we first need to know who is ordering, which is when you continue to the kickoff step or when we check your VAT number. It keeps the checkout steps from being misused and expires after two hours.
• The calendar’s own necessary storage on cal.firogrowth.com, used when you book a time.
• Stripe’s fraud-prevention cookies, set only when the Stripe payment form loads.

The site uses no advertising or tracking cookies.

All of this is necessary for the site to work, so we do not ask for consent. You can clear it in your browser at any time.

We update this notice when the site or our providers change. The new version applies from the day we publish it on this page. This is version 2026-09-29.