Privacy Policy

1. Introduction

This Privacy Policy explains how the Company collects, uses, shares, and protects information in connection with Feel Great HQ and our related websites and services. “Company,” “we,” “us,” and “our” mean Tonioli Music, LLC, doing business as Grow Well and Grow Well HQ, and operating GrowHQ, the Feel Great HQ application, ifeelgreat.link, feelgreathq.com, and growhq.io.

Feel Great HQ is the name of an app and service operated by the Company. It is not a separate legal entity.

Contact:

Tonioli Music, LLC doing business as Grow Well and Grow Well HQ 5948 W 5500 S Hooper, UT 84315-9998 Email: privacy@growhq.io

2. Key definitions

Customer, User, or Page Owner means a person or business that creates an account, builds pages, collects leads, or uses the dashboard.

End User, Visitor, or Lead means a person who visits a Customer page, clicks a link, submits a form, requests a resource, or otherwise interacts with a Customer page.

Customer Page means a page, link hub, landing page, form, or other public-facing page created by a Customer using the Services.

Customer Lead Data means personal information submitted by End Users through Customer Pages or processed through the Services on behalf of a Customer. Customer Lead Data may include names, email addresses, phone numbers, form responses, page URLs, page owner identifiers, timestamps, consent records, delivery records, and other information submitted by End Users or configured by Customers. Depending on page type, visitor location, tracking mode, security needs, and feature configuration, related metadata may include IP address, user agent, device/browser information, referrer, approximate country-level location, and technical logs.

3. Our privacy role

For Customer account data, billing data, website data, support data, security data, and Company marketing data, the Company generally acts as an independent controller or business.

For Customer Lead Data submitted through Customer Pages, the Customer generally acts as the controller or business, and the Company generally acts as a service provider, contractor, or processor. In that role, we process Customer Lead Data to provide the Services on behalf of the Customer.

Feel Great HQ does not use information submitted through Customer pages to market Feel Great HQ, GrowHQ, Grow Well, Grow Well HQ, or related Company services to End Users unless the End User separately opts in directly to receive communications from us.

4. Information we collect

Customers may provide name, email address, phone number, business name, account login information, billing and subscription information, profile information, page content, links, images, videos, lead magnets, form fields, disclosures, support messages, settings, preferences, team member information, and information needed to connect HighLevel or other integrations.

Depending on how a Customer configures a page, End Users may provide name, email address, phone number, form responses, message content, requested resource information, consent selections, and other information the Customer chooses to collect.

When someone uses the Services or visits a Customer Page, we may collect IP address, device type, browser type, operating system, user agent, referring URL, pages viewed, timestamps, approximate location derived from IP address, cookies, local storage identifiers, similar technical identifiers, log data, security data, and error data, subject to the tracking mode and restrictions described below.

We currently track total page views for certain public pages. We may also track unique page views where permitted by our tracking mode, visitor location, browser settings, and applicable law. In restricted regions, unique visitor tracking may be disabled or limited, and dashboard metrics may be less precise.

If a Customer connects HighLevel or another third-party service, we may collect and process information needed to operate the integration, such as account identifiers, authorization tokens, contact records, form submissions, workflow information, message records, and integration logs. The Customer controls whether to connect those services and is responsible for compliance with the third-party service's terms and legal requirements.

Payments may be processed by third-party payment processors if paid services are offered. We may receive limited billing information, transaction status, subscription status, and payment metadata. We do not intentionally store full payment card numbers unless explicitly stated by the payment processor or required for a specific payment feature.

5. Regional Tracking Modes

We use different tracking modes depending on visitor location, page type, and feature configuration.

For visitors who appear to be located in the EEA, United Kingdom, or Switzerland, and for visitors whose location cannot be determined, we restrict non-essential analytics tracking on public End User-facing pages. In restricted mode, we do not set or read the fghq_vid analytics cookie, feelGreatHq.visitorKey in localStorage, feelGreatHq.sessionId in sessionStorage, or similar persistent browser identifiers for public page analytics.

In restricted mode, we do not send visitor-level or session-level analytics events, do not associate public funnel page views or clicks with an End User record, and do not create persistent browser identifiers for public page analytics.

We may still process limited server-side request information, such as request time, requested page, general country-level location, IP address, user agent, referrer, and technical logs, for security, debugging, service operation, abuse prevention, and aggregate analytics. Where we use aggregate analytics in restricted mode, we do so without non-essential browser storage, visitor IDs, session IDs, fingerprinting, or user-level event trails.

We may process country-level location signals derived from a visitor's IP address to determine whether public analytics should operate in full mode or restricted mode. We use this country-level signal for privacy-mode selection, security, service operation, and compliance purposes.

6. How we use information

We use information to:

• provide, operate, maintain, and secure the Services;
• create and host Customer Pages;
• collect, store, and display form submissions to Customers;
• deliver requested resources or lead magnets;
• send transactional or relationship emails from Company domains on behalf of Customers;
• track total page views and, where permitted by our tracking mode, visitor location, browser settings, and applicable law, unique page views;
• provide dashboards and reporting;
• support HighLevel and other integrations;
• process payments and subscriptions if applicable;
• respond to support requests;
• prevent fraud, spam, abuse, and unauthorized access;
• debug and improve the Services;
• communicate with Customers about their accounts;
• send Company marketing to Customers and people who directly opt in to Company communications;
• enforce our Terms and policies;
• comply with legal obligations;
• create aggregated or de-identified information.

7. Transactional email to End Users

The Services may send transactional or relationship emails from Company-controlled sending domains on behalf of Customers. Examples include delivering a requested resource, sending a lead magnet, confirming a form submission, or providing a link requested by the End User.

These emails are sent to provide the Customer-configured service requested by the End User. Feel Great HQ does not add End Users to the Company's own marketing list unless the End User separately and directly opts in to Company communications.

8. SMS and calling

Feel Great HQ does not send SMS messages to End Users on behalf of Customers from a shared Company SMS number.

If a Customer uses HighLevel or another connected service for SMS, calls, voicemail, or similar communications, the Customer is responsible for consent, registration, message content, opt-outs, and legal compliance for those communications. The Company may process or transmit relevant contact data to the connected service as instructed by the Customer.

9. How we share information

When an End User submits a form on a Customer Page, we share the submitted information and related submission data with the Customer who owns or controls that page.

We may share information with service providers and subprocessors that help us operate the Services, including hosting providers, database providers, storage providers, authentication providers, video delivery providers, security vendors, support tools, and integration providers.

If a Customer connects HighLevel or another third-party service, we may share information with that service as directed by the Customer.

We may disclose information if we believe disclosure is necessary to comply with law, respond to legal process, enforce our Terms, prevent fraud or abuse, protect rights or safety, investigate security issues, or in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction.

We may use and share aggregated or de-identified information that does not reasonably identify a person.

10. No sale or sharing of Customer Lead Data for Company marketing

We do not sell Customer Lead Data. We do not share Customer Lead Data for cross-context behavioral advertising. We do not use Customer Lead Data to market our own services to End Users unless the End User separately opts in directly to the Company.

If we introduce advertising pixels or other tracking technologies that materially change this practice, we will update this Privacy Policy and provide any legally required choices.

11. Customer pixels and third-party tracking

Customer-controlled pixels, scripts, tags, cookies, analytics tools, advertising tools, retargeting tools, conversion APIs, and similar tracking technologies may be disabled, blocked, or restricted by default in certain regions unless and until appropriate consent controls are available or enabled. Customers are responsible for their own use of Meta/Facebook Pixel, Google tags, analytics tools, advertising pixels, retargeting tools, affiliate tracking, conversion APIs, and similar technologies.

If a Customer uses third-party tracking or links to third-party websites, those third parties may collect information under their own terms and policies. The Company is not responsible for Customer-controlled third-party tracking.

12. Cookies and similar technologies

We use cookies, local storage, server logs, and similar technologies to operate the Services, maintain sessions, secure accounts, remember settings, count page views where permitted by the applicable tracking mode, detect abuse, and understand usage. See our Cookie Policy for more information.

13. Data retention

We retain information for as long as reasonably necessary to provide the Services, maintain accounts, comply with law, resolve disputes, enforce agreements, maintain security, and keep legitimate business records.

Customer Lead Data is generally retained while the Customer account is active or until the Customer deletes it, requests deletion, or closes the account, subject to backups, legal obligations, security needs, and legitimate recordkeeping.

Transactional logs, consent records, security logs, and audit records may be retained longer where needed for compliance, fraud prevention, dispute resolution, or legal protection.

14. Your privacy choices

Customers may access, update, export, or delete certain account and lead information through the dashboard, depending on available features.

End Users who want to access, correct, delete, or opt out of use of Customer Lead Data should usually contact the Customer or Page Owner directly because the Customer controls that data. End Users may also contact privacy@growhq.io, and we may assist, respond, or forward the request to the relevant Customer as appropriate.

Marketing emails from the Company to Customers include unsubscribe instructions where required. Transactional emails may not include an unsubscribe link if they are necessary to provide a requested transaction or account-related service.

15. U.S. state privacy rights

Depending on where you live, you may have rights to request access, correction, deletion, portability, restriction, or opt-out of certain uses of personal information. You may also have the right to appeal a privacy request decision.

To exercise rights, contact privacy@growhq.io. We may need to verify your identity before responding. For Customer Lead Data, we may direct the request to the relevant Customer or process the request on the Customer's behalf.

California notice: We collect the categories of personal information described in this Privacy Policy, including identifiers, contact information, commercial information, internet or network activity, approximate geolocation, audio/visual or electronic information where voluntarily provided, professional or business information where provided, and inferences or preferences where generated by account settings or usage. We collect this information from you, Customers, End Users, devices, service providers, and connected integrations. We use and disclose it for the purposes described above. We do not sell Customer Lead Data or share Customer Lead Data for cross-context behavioral advertising.

16. International users

The Services are operated primarily from the United States. If you access the Services from outside the United States, your information may be processed in the United States and other countries that may have different data protection laws.

If GDPR, UK GDPR, or similar laws apply, the Company acts as a controller for Company account, billing, website, security, support, and operational data, and as a processor for Customer Lead Data processed on behalf of Customers. Legal bases may include contract performance, legitimate interests, consent, and legal compliance, depending on the context.

Customers are responsible for determining and documenting their own lawful basis for collecting and using Customer Lead Data.

17. Children and sensitive information

The Services are not directed to children under 13. Customers may not use the Services to knowingly collect personal information from children under 13.

The Services are not designed to collect medical records, protected health information, financial account information, Social Security numbers, government identification numbers, children's information, precise location, biometric data, or other sensitive personal information. Customers may not collect sensitive information through the Services unless expressly authorized by the Company in writing and legally compliant.

18. Security

We use reasonable safeguards designed to protect personal information. No method of transmission or storage is completely secure. Customers are responsible for securing their accounts, passwords, devices, exports, connected integrations, and team access.

19. Reporting a Customer Page

If you believe a Customer Page violates our policies, misuses personal information, infringes rights, includes abusive content, or creates another privacy or safety concern, you may report it at https://feelgreathq.com/report or email privacy@growhq.io. Copyright or DMCA notices should be sent to dmca@growhq.io.

When you report a page, include the page URL and enough detail for us to review the issue. We may review the report, contact the Page Owner, restrict or remove content, or take other action where appropriate.

20. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will update the Last updated date when changes are made. Continued use of the Services after changes become effective means you acknowledge the updated policy.

21. Contact

For privacy questions or requests, contact:

Tonioli Music, LLC doing business as Grow Well and Grow Well HQ 5948 W 5500 S Hooper, UT 84315-9998 Email: privacy@growhq.io