Effective Date: March 5, 2026  ·  learning.growthholistics.com  ·  hello@growthholistics.com

1.  Who We Are

Growth Holistics Learning (“we,” “us,” or “our”) is the personal information controller responsible for your personal data collected through learning.growthholistics.com in connection with the “Tanging Tahanan” online course. You may contact our designated Data Protection contact at hello@growthholistics.com.

2.  Personal Data We Collect

2.1  Information You Provide Directly

When you register for or enroll in the course, we may collect:

• Full name;

• Email address;

• Affiliations;

• Ethnic identity;

• Password (stored in encrypted/hashed form);

• Payment information (processed securely by our third-party payment processor — we do not store full card details);

• Billing address (if required for payment processing);

• Communication preferences.

2.2  Information Collected Automatically

When you access the Platform, we may automatically collect:

• Device type, operating system, and browser type;

• IP address and general location (country/region level);

• Pages visited, lesson completion data, and time spent on content;

• Referring website or link;

• Cookies and similar tracking technologies (see Section 7).

2.3  Information from Third Parties

We may receive limited information from payment processors (e.g., transaction confirmation) or other integrated tools used to operate the Platform.

3.  How We Use Your Personal Data

We use your personal data for the following purposes:

• To process your enrollment and provide access to the course;

• To communicate with you about your enrollment, course updates, and support;

• To send you relevant emails about your course progress, new resources, or related programs (you may opt out at any time);

• To process payments and issue receipts;

• To improve the quality and delivery of our course content;

• To comply with legal and regulatory obligations under Philippine law;

• To protect the security and integrity of the Platform.

4.  Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), we process your personal data based on the following lawful criteria:

• Consent: You have given us your consent upon enrollment and acceptance of these policies;

• Contract: Processing is necessary to fulfill our obligations under the enrollment agreement;

• Legitimate Interests: Processing is necessary for our legitimate interests in operating and improving the course, provided these do not override your rights;

• Legal Obligation: Processing is required to comply with applicable Philippine laws.

5.  Sharing of Personal Data

5.1  Third-Party Service Providers

We may share your personal data with trusted third-party service providers who assist us in operating the Platform and delivering the course, including:

• Course and Learning Management System (LMS) providers;

• Payment processors (e.g., Stripe, PayMongo, or similar);

• Email marketing platforms;

• Video hosting services;

• Analytics tools.

These service providers are required to handle your data securely and only for the purposes for which it was shared.

5.2  Legal Disclosures

We may disclose your personal data if required to do so by law, court order, or by a government authority in the Philippines, or to protect the rights and safety of our students and team.

5.3  No Sale of Personal Data

We do not sell, rent, or trade your personal information to any third party for marketing purposes.

6.  Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, and in accordance with our legal obligations under Philippine law. Specifically:

• Account and enrollment data: Retained for the duration of your access to the course and for a reasonable period thereafter (typically 3 years) for record-keeping purposes;

• Payment records: Retained for at least 5 years as required by Philippine tax and accounting regulations;

• Communications: Retained for up to 2 years from the date of last interaction.

When data is no longer needed, it will be securely deleted or anonymized.

7.  Cookies and Tracking Technologies

Our Platform uses cookies and similar tracking technologies to enhance your learning experience. Cookies are small files stored on your device. We use:

• Essential cookies: Necessary for the Platform to function (e.g., login sessions);

• Functional cookies: To remember your preferences and progress;

• Analytics cookies: To understand how the Platform is used and improve the course.

You can control cookie settings through your browser settings. Disabling certain cookies may affect your ability to use some features of the Platform.

8.  Your Rights Under the Data Privacy Act of 2012

As a data subject under RA 10173, you have the following rights:

• Right to be informed: You have the right to know what personal data we collect and how we use it;

• Right to access: You may request a copy of the personal data we hold about you;

• Right to rectification: You may request correction of inaccurate or incomplete data;

• Right to erasure or blocking: You may request deletion of your personal data under certain circumstances;

• Right to object: You may object to the processing of your personal data for certain purposes (e.g., direct marketing);

• Right to data portability: You may request your data in a commonly used electronic format;

• Right to lodge a complaint: You may file a complaint with the National Privacy Commission (NPC) of the Philippines at https://www.privacy.gov.ph.

To exercise any of these rights, please contact us at hello@growthholistics.com.

9.  Data Security

We implement reasonable technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These include encrypted data transmission (HTTPS), secure password storage (hashing), and access controls for our team members who handle personal data.

While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that affects your rights, we will notify you and the National Privacy Commission in accordance with RA 10173.

10.  Children’s Privacy

Our course is intended for individuals aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18 without verifiable parental consent. If you believe a minor has provided us with personal data without consent, please contact us at hello@growthholistics.com and we will take steps to remove such information.

11.  International Data Transfers

Our Platform may use third-party services hosted outside the Philippines. When your data is transferred internationally, we ensure that adequate safeguards are in place in accordance with RA 10173 and NPC guidelines.

12.  Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify enrolled students of material changes by email and will update the effective date at the top of this policy. Continued use of the Platform after changes constitutes your acceptance of the updated policy.

13.  Contact Us

For privacy-related inquiries, data access requests, or complaints:

• Email: hello@growthholistics.com 

• Website: learning.growthholistics.com 

• Company: Growth Holistics FZC LLC

• For complaints unresolved by us, you may contact the National Privacy Commission at https://www.privacy.gov.ph .