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Consultation

Privacy Policy

Last updated on July 15, 2025

1. INTRODUCTION

This Privacy Policy (hereinafter referred to as the “Policy”) provides a clear and comprehensive explanation of how UAB Manimama Growth, a company incorporated under the laws of Lithuania, under registered number 305935776, having legal address at: Eišiškių Sodų 18-oji g. 11, LT-02194, Vilnius, Lithuania (referred to as the “Company”, “ManiMama Growth Agency”, “We”, or “Us”) collect, process, and share your personal data, as well as the security measures We have in place to protect Your personal data and the rights in relation to Your personal information. 

We are committed to protecting your data privacy and data security according to the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred to as the “GDPR”) and other applicable legislation.

By using our Services, you confirm that you have fully read, understood, and agreed to all the terms and conditions stated in this Privacy Policy. If you find any part of this Privacy Policy unacceptable, we recommend that you refrain from accessing or using any of the Services provided by Us. All terms in this Policy align with Our Terms of Use (Public Offer Agreement) (hereinafter referred to as the “Terms of Use”, “Agreement”, “Public Offer” or “Terms”) and Cookies Policy.

If you consider any term or condition of this Policy inappropriate, please do not visit, access or use our Website or Services.

2. DEFINITIONS

Applicable Laws – all applicable laws, statutes, regulations and codes from time to time in force.

Client – any natural or legal person who applies for, accesses, or uses the Services provided by the Company under Our Terms, regardless of the method of communication or payment used.

Service – any consulting service provided by the Company to the Client under the Agreement, including but not limited to: strategic business planning, financial and investment consulting, legal structuring and international tax planning, business development support, assistance with startup launches and scaling, market and business model analysis, preparation of analytical materials and recommendations, training sessions, recruiting, and any other related services listed or referenced on the official Website.

Parties – collectively, the Company and the Client who enter into a contractual relationship based on the Terms of Use.

Website – the official website of the Company (available at the link https://manimamagrowth.com/), where information regarding the Services, legal documents, updates, contact details, and any public Offers are published.

Personal Data – any information relating to an identified or identifiable natural person. 

Data Subject – an identifiable natural person, who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Accept – the Client’s expressed consent to enter into the Agreement by submitting a completed request, making payment, or taking any other action that indicates agreement with the Terms of Use.

Fee – the financial remuneration payable by the Client to the Company for the provision of Services, as agreed in the Service Agreement, Order Confirmation, invoice, or as published on the Website.

Order – a specific request or assignment initiated by the Client and accepted by the Company, which determines the scope, format, and terms of a particular Service provision within the framework of the Agreement.

Offer (Public) – the Company’s public offer to provide Services, addressed to an indefinite number of persons, which becomes binding upon its acceptance by the Client in accordance with the Terms of Use.

Data Controller – the Company, as the legal person that manages the database and/or repository, or determines the purposes and means of processing the personal data that they administer or possess, and is responsible for ensuring that such processing is carried out in accordance with applicable data protection laws.

Data Processing – any operation or set of operations carried out by automated or manual procedures and applied to personal data. This includes the collection, use, recording, organization, storage, retention, dissemination, possession, access, management, and disclosure of personal data.

3. DATA WE COLLECT

3.1. When you use the Our Services or interact with Our Website, We collect the information in the following ways:

3.2. Information You Provide Voluntarily: 

3.2.1. We collect personal data that you choose to share with us directly, including but not limited to:

  • Full name, email address, and contact details;
  • Company or organizational information;
  • Responses to surveys, forms, or applications;
  • Any correspondence or communication with our team;
  • Information submitted through service requests or contracts.

This data is primarily collected when completing the Consultation form or any other types of forms on our Website.

3.3. Information Collected Automatically:

3.3.1. We collect certain data automatically when you interact with Our Website or digital Services. This includes:

Technical Information:

  • IP address;
  • Browser type and version;
  • Operating system and device type;
  • Referring URL and time zone settings.

Usage Data:

  • Pages visited and actions taken on the Website;
  • Session duration and interaction data.

3.4. Cookies and Tracking Technologies.

3.4.1. We use cookies and similar technologies to enhance Your experience, monitor performance, and personalize content. The categories of data collected include:

  • Unique identifiers (e.g., _ga) used for analytics;
  • Session identifiers used to maintain secure login and navigation;
  • Behavioral data used for advertising personalization (e.g., _gcl_au, test_cookie);
  • Browser capabilities, including cookie support status.

For more details, please refer to Our Cookie Policy.

3.5. Third-Party Data Sources.

3.5.1. We may receive personal data from:

Public sources or marketing platforms (where legally permitted);

Analytics providers (e.g., Google Analytics) for aggregated usage metrics.

4. HOW WE USE YOUR INFORMATION

4.1. We collect and process Your information in order to operate Our Services effectively, ensure legal compliance, and enhance Your experience on Our Website. The information We collect may be used for the following purposes:

4.1.1. Service Delivery and Client Relationship:

  • To provide consulting services;
  • To respond to Your inquiries, service requests, and communication;
  • To send essential updates and service-related messages;
  • To personalize service delivery based on Your submitted preferences or business needs.

4.1.2. Analytics and Performance Optimization:

  • To analyze Website traffic, behavior, and performance using tools;
  • To evaluate the effectiveness of marketing campaigns and Client engagement;
  • To identify usage patterns and improve Website navigation and Service offerings.

4.1.3. Security and Platform Functionality:

  • To maintain the technical stability, availability, and security of Our Website;
  • To detect, prevent, and mitigate fraudulent or unauthorized activities;
  • To support system diagnostics, incident response, and risk assessments.

4.1.4. Marketing and Advertising:

  • To deliver tailored advertisements through cookies (e.g., Google Ads);
  • To measure the performance of ad campaigns across the Website and optimize ad placements;
  • To retarget Clients who previously interacted with Our content or Services.

4.1.5. Internal Operations and Strategic Development:

  • To generate anonymized statistical reports and market intelligence;
  • To assess Client needs and adapt Our product or Service strategy;
  • To audit internal processes and ensure quality assurance.
5. WHAT IS THE LEGAL BASIS FOR COLLECTING YOUR PERSONAL DATA?

5.1. In compliance with the GDPR and other applicable data protection laws, We rely on a range of legal bases for processing your personal data. The legal bases are as follows:

  • your consent – you give us consent for the processing of your personal data;
  • the performance of a contract – We rely on this basis when processing your personal data to perform our contractual obligations to you in order to provide our Services;
  • compliance with a legal obligation to which We are subject – your personal data may be used as necessary for the fulfillment of the legal obligation itself;
  • legitimate Interests – We rely on this basis in cases where it is necessary for us to process your personal data to meet our own needs for the operation, management and development of our business or to protect legitimate interests that We or a third party pursue (provided that a balance of interests is achieved).

5.2. We will be pleased to assist in clarifying the specific legal basis on which processing is carried out in any case.

6. RIGHTS OF DATA SUBJECTS

6.1. As a Client of Our Company, You are entitled to exercise specific rights under applicable data protection laws, including the GDPR. These rights are aimed at giving You greater transparency and control over your personal data.

6.2. Right of Access.

You have the right to obtain confirmation as to whether or not Your personal data is being processed, and, where it is, to access that data along with information about:

  • The purposes of processing;
  • The categories of data concerned;
  • The recipients or categories of recipients;
  • The intended data retention period;
  • Your rights related to correction, deletion, and objection;
  • The source of the data (if not collected directly from you);
  • The existence of automated decision-making or profiling and related safeguards;
  • If data is transferred internationally, the relevant safeguards in place.

6.3. Right to Rectification.

You have the right to request the correction of inaccurate personal data, or to have incomplete data completed.

6.4. Right to Erasure (Right to be Forgotten).

You may request that we delete Your personal data when:

  • It is no longer necessary for the purposes for which it was collected;
  • You withdraw consent and no other legal basis applies;
  • You object to the processing and there are no overriding legitimate grounds;
  • The data was unlawfully processed or must be erased to comply with legal obligations.

6.5. Right to Restriction of Processing.

You have the right to limit the processing of your data in cases where:

  • You contest its accuracy;
  • The processing is unlawful, but you oppose erasure;
  • The data is no longer needed by us, but you need it for legal claims;
  • You have objected to the processing and we are verifying legitimate grounds.

6.6. Right to Data Portability.

You may request to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller, where technically feasible.

6.7. Right to Object.

You may object to the processing of Your personal data at any time when it is:

  • Based on Our legitimate interests;
  • Used for direct marketing purposes.

We will stop processing unless We demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

6.8. Rights Related to Automated Decision-Making and Profiling.

You have the right not to be subject to a decision based solely on automated processing, including profiling, if it produces legal or similarly significant effects on You – unless necessary for a contract, authorized by law, or based on explicit consent, with appropriate safeguards in place.

6.9. Right to Withdraw Consent.

Where processing is based on Your consent, You may withdraw it at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

7. DATA SECURITY

7.1. We place a high priority on the security of your personal data. The Company employs appropriate technical and organizational measures to protect your information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures are designed in accordance with applicable data protection laws and industry-recognized security standards.

7.2. While We are dedicated to maintaining strong data protection practices and utilize industry-accepted technologies and controls, it is important to acknowledge that no method of electronic transmission or data storage can be entirely risk-free. Therefore, although We take all reasonable steps to safeguard your data, We cannot guarantee its absolute security.

8. PERSONAL DATA RETENTION PERIOD

8.1. We will retain Your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to meet legal, regulatory, accounting, or reporting obligations, to comply with applicable Anti-Money Laundering laws and to resolve any potential disputes or legal claims.

8.2. The exact retention period may vary depending on factors such as the nature of the data, the legal basis for its processing, the purpose for which it was collected, and Our operational requirements.

8.3. Please also note that in accordance with Our legal or regulatory obligations and international data retention standards, you give Us your consent and permission to store Your personal data for the entire duration of the business relationship with You and for a period of five years after the termination of the business relationship.

9. CHILDREN’S DATA PROTECTION

9.1. The protection of children’s personal data is of paramount importance to Us. 

9.2. The Company does not knowingly collect or process personal data from individuals under the age of 18. By using our Services, Clients confirm that they are at least 18 years of age.  If we learn that we have inadvertently collected personal data from a child under the age of 18, we will take immediate steps to delete that data from our systems.

9.3. Parents and legal guardians who believe that we may have collected information from a child under the age of 18 are encouraged to contact us immediately using the contact details provided in this Policy.

9.4. We do not offer Services or content that is targeted specifically at minors, nor do we use profiling or behavioral targeting aimed at Clients under the age of 18.

10. AMENDMENTS AND NOTICES

10.1. The Company reserves the right to revise, update or modify this Policy at any time, in whole or in part, to take into account changes in applicable laws, technological advances, business operations or others.

10.2. Material changes to the Policy will be announced by publication on the Site and/or through official communication channels such as email, Telegram or other methods specified by the Company. Unless otherwise specified, such changes will be effective immediately upon publication on the Site, and such publication will be deemed appropriate to notify the Client of the changes.

10.3. By continuing to access or use the Services after the implementation of the updated Policy, the Client confirms their acceptance of an agreement to be legally bound by the revised Privacy Policy. If the Client does not agree to any changes, they must immediately terminate their cooperation.

10.4. All official notices from the Company are deemed to have been actually delivered if sent to the most recent contact information provided by the Client, whether during the initial communication or through later updates. The Client is solely responsible for maintaining the accuracy and completeness of its contact details at all times.

10.5. The Company shall not be liable for any failure to deliver notices as a result of out-of-date or incorrect contact information.

10.6. All notices and communications under this Policy shall be made in English.

11. CONTACT DETAILS

11.1. If You have any questions, comments, or requests regarding these Terms or the Services provided, You may contact the Company using the following details:

11.2. The Company reserves the right, at its sole discretion, to modify or update these Terms at any time. The most current version of the Terms shall prevail over any previous versions and will be made available on the Company’s official website. Clients are encouraged to review the Terms periodically in order to remain informed of any changes.