A DIFFERENT APPROACH

Smart Money Growth Privacy Policy.

# Privacy Policy
Effective Date: 29 November 2025
1. Introduction
Smart Money Growth ("we," "us," or "our") is an educational practice based in Luxembourg dedicated to providing financial literacy and investment frameworks. We respect your privacy and are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR).
This policy explains how we collect, use, and protect your information when you visit our website, download our resources, or apply for our programs.2. Who Is Responsible (Data Controller)
The data controller responsible for your information is:
Romain Lucas (trading as Smart Money Growth)
Location: Luxembourg
Contact: [email protected]
3. What Data We Collect
We collect limited personal data necessary to deliver our educational services and communicate with you.
* Identity Data: First name, last name.
* Contact Data: Email address.
* Technical Data: IP address, browser type, and usage data (via cookies).
* Application Data: Information you voluntarily provide when applying for the "Strategic Session" or "Mastery Program" (e.g., investment goals, current portfolio status).
4. How We Use Your Data
We use your data for specific, transparent purposes:
* To Deliver Assets: Sending you the "Clarity Guide," "Cost of Inaction" results, or other requested resources.
* To Educate & Communicate: Sending you the "Rational Investor" email series and updates about workshops or market insights.
* To Process Applications: Reviewing your suitability for our high-ticket mentorship programs.
* To Improve Our Service: Analyzing website traffic to understand user needs.
Our "Zero Sale" Promise:
We are an unconflicted education practice. We never sell, rent, or trade your personal data to third parties, banks, or financial institutions. Your data stays with us.
5. Third-Party Processors
To operate our business efficiently, we use trusted third-party service providers. We ensure these providers comply with strict data protection standards.
* Carrd: Website hosting and landing pages.
* MailerLite: Email marketing and newsletter delivery.
* Stripe: Secure payment processing (we do not store credit card details).
* Google Analytics (GA4): Anonymous website traffic analysis.
* Meta (Facebook/Instagram): Ad performance tracking (via Pixel).
* Notion: Internal client relationship management (CRM).
6. Your Rights (GDPR)
Under the GDPR, you have the following rights regarding your data:
* Right to Access: You can request a copy of the data we hold about you.
* Right to Rectification: You can ask us to correct inaccurate data.
* Right to Erasure ("Right to be Forgotten"): You can ask us to delete your data at any time.
* Right to Unsubscribe: Every email we send contains a clear "Unsubscribe" link.
To exercise any of these rights, simply email [email protected].7. Cookies & Tracking
We use cookies to enhance your browsing experience and analyze site traffic.
* Functional Cookies: Necessary for the website to function.
* Analytics Cookies: Used by Google Analytics to help us understand how visitors use the site.
* Marketing Cookies: Used by Meta to measure the effectiveness of our advertising campaigns.
You can control or disable cookies through your browser settings.8. Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. Any changes will be posted on this page.

© Smart Money Growth. All rights reserved.
Smart Money Growth and Romain provide financial education and coaching services. We do not provide investment advice, individual recommendations, or manage investments on behalf of clients. The information shared on this website, the guide, during workshop/strategic sessions, mentorship sessions or through any other content is for informational and educational purposes only.
It is not intended to constitute legal, tax, or investment advice, nor an offer or solicitation to buy or sell any financial product.Each individual is responsible for their own investment decisions. If you require personalized financial advice, please consult a licensed financial advisor or other qualified professional.