Harvested

Privacy Policy and Personal Data Processing Policy

Last updated: August 12, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service, and tells You about Your privacy rights and how the law protects You. It also serves as Our personal data processing policy: it sets out who processes Your Personal Data, on what grounds, for what purposes, and for how long.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Data Controller

The controller responsible for processing Your Personal Data is:

  • Individual Entrepreneur Ekaterina Lashko, operating under the trade name “Harvested”
  • State registration number: 286.1471569, dated 5 August 2025
  • Taxpayer identification number (TIN/HVHH): 40311316
  • Registered address: 26A Khorenatsi Street, office 201, Kentron, 0010 Yerevan, Republic of Armenia
  • Email: harvested.app@gmail.com
  • Phone: +374 55 623 244

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access the Service or parts of the Service, including free lessons and purchased Courses.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our”) refers to Individual Entrepreneur Ekaterina Lashko, registered in the Republic of Armenia (state registration number 286.1471569, dated 5 August 2025; taxpayer identification number (TIN/HVHH) 40311316), registered address: 26A Khorenatsi Street, office 201, Kentron, 0010 Yerevan, Republic of Armenia, operating under the trade name “Harvested”.
  • Cookies are small files that are placed on Your Device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: Armenia.
  • Course means an online educational course offered by the Company through the Service.
  • Device means any device that can access the Service, such as a computer, a cell phone or a digital tablet.
  • Personal Data (or “Personal Information”) is any information that relates to an identified or identifiable individual. We use “Personal Data” and “Personal Information” interchangeably unless a law uses a specific term.
  • Service refers to the Website located at https://start-growing.com, including the Courses, lessons, downloadable materials and related features made available through it.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Account login credentials (Your password is stored in encrypted form and is not visible to Us)
  • The content of messages You send Us through the contact form
  • Billing information such as billing name, billing address and country, where required to complete a purchase
  • Records of Courses You have purchased, Your enrollment date and Your progress through lessons

We do not collect or store Your full payment card number, expiry date or security code. Payment card details are entered directly with Our payment processor and are processed by them in accordance with their own privacy policy and applicable payment card industry standards.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type and version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, the referring page, unique device identifiers, approximate location derived from Your IP address, and other diagnostic data.

When You access the Service through a mobile device, We may collect certain information automatically, including the type of mobile device You use, Your mobile operating system, and the type of mobile Internet browser You use.

Course Progress Data

When You are logged in to Your Account, the Service records which lessons You have opened and completed so that Your progress is saved and carries over between sessions and devices, including from the free lessons to a purchased Course.

Cookies and Similar Technologies

We use Cookies and similar tracking technologies to operate the Service and to understand how it is used. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. If You do not accept Cookies, You may not be able to use some parts of Our Service, including logging in to Your Account.

We use the following categories:

  • Strictly Necessary Cookies. Required to operate the Service, to authenticate You, to keep You logged in, to remember the contents of Your order and to provide security features. These cannot be switched off in Our systems.
  • Functionality Cookies. Allow Us to remember choices You make, such as Your language preference and Your login details, so that You do not have to re-enter them.
  • Analytics Cookies. Help Us understand how visitors interact with the Service, which pages are visited most often, and where visitors encounter difficulties, so that We can improve the Service. We use Google Analytics for this purpose, as described in the section “Analytics” below. These Cookies are set only where You have given Your consent, and You may withdraw that consent at any time through the cookie settings on the Service.

“Do Not Track” Signals

Do Not Track (“DNT”) is a preference You can set in Your web browser to inform websites that You do not want to be tracked. At this time, there is no uniform technology standard for recognizing and implementing DNT signals. Accordingly, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates Your choice not to be tracked. If a standard for online tracking is adopted that We must follow in the future, We will inform You about that practice in a revised version of this Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain the Service, including to monitor the usage of the Service and to keep it secure and available.
  • To create and manage Your Account, to authenticate You and to give You access to the free lessons and to the Courses You have purchased.
  • To perform Our contract with You, including processing Your enrollment, taking payment, issuing invoices and receipts, delivering access to Course content and downloadable materials, and handling refund requests.
  • To save and restore Your Course progress across sessions and devices.
  • To contact You by email regarding Your Account, Your purchases, changes or updates to a Course You have enrolled in, and other service-related messages.
  • To respond to Your enquiries submitted through the contact form or sent to Us by email, and to provide customer support.
  • To send You marketing communications about new Courses, guides, offers and related news, where You have subscribed or where We are otherwise permitted to do so by law. You may opt out at any time.
  • To improve the Service, by analysing usage trends, identifying which content is helpful, testing new features and measuring the effectiveness of Our communications.
  • To prevent fraud and misuse, including detecting unauthorized sharing of Account credentials or Course content, and enforcing Our Terms of Service.
  • To comply with legal obligations, including accounting, tax and consumer protection requirements.
  • For business transfers, to evaluate or conduct a merger, restructuring, reorganization, or sale or transfer of some or all of Our assets, in which Personal Data held by Us about users of the Service is among the assets transferred.

Legal Bases for Processing (GDPR)

If You are located in the European Economic Area or the United Kingdom, We process Your Personal Data only where We have a legal basis to do so. The legal bases We rely on are:

  • Performance of a contract. Processing necessary to provide the Service You have signed up for or purchased: creating and maintaining Your Account, delivering Course access, saving Your progress, taking payment and handling refunds.
  • Legitimate interests. Processing necessary for Our legitimate interests, provided those interests are not overridden by Your rights: securing the Service, preventing fraud and unauthorized sharing of paid content, understanding how the Service is used in order to improve it, responding to Your enquiries, and sending existing customers information about similar Courses.
  • Consent. Where You have given consent, for example for non-essential analytics Cookies and for marketing emails You subscribe to. You may withdraw Your consent at any time; withdrawal does not affect the lawfulness of processing carried out before withdrawal.
  • Legal obligation. Processing necessary to comply with the law, such as retaining invoices and transaction records for tax and accounting purposes.

Email Communications

We distinguish between two types of email:

  • Service and transactional emails are sent in connection with Your Account and Your purchases — for example, account confirmation, password resets, receipts, access details, and important notices about a Course You have enrolled in or about changes to these policies. These are part of the Service and cannot be opted out of while You hold an Account, other than by closing Your Account.
  • Marketing emails are sent only where You have subscribed or otherwise consented, and may include announcements of new Courses, guides, discounts and other news. You can unsubscribe at any time using the link at the bottom of any marketing email, or by contacting Us at the address at the end of this Privacy Policy. Unsubscribing from marketing emails does not stop service and transactional emails.

Emails are currently sent from Our own mail system and Your email address is not shared with a third-party marketing platform. If this changes, We will update this Privacy Policy and name the provider before the change takes effect.

Disclosure of Your Personal Data

We may share Your Personal Data in the following situations:

  • With Service Providers. We share Personal Data with third parties who perform services on Our behalf, including website and course hosting, payment processing, email delivery, and analytics. These providers may access Personal Data only to perform these tasks on Our behalf and are obliged not to disclose or use it for any other purpose.
  • For legal reasons. We may disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (for example a court or a government agency), or where We believe in good faith that disclosure is necessary to comply with a legal obligation, protect and defend Our rights or property, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of users of the Service or the public, or protect against legal liability.
  • For business transfers. We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing or acquisition of all or a portion of Our business.
  • With Your consent. We may disclose Your Personal Data for any other purpose with Your consent.

We do not sell Your Personal Data, and We do not share it with third parties for their own independent marketing purposes.

The third-party providers We currently rely on are:

  • Payment processing: a licensed bank in the Republic of Armenia acting as Our acquiring bank, through its virtual POS terminal service. Card details are entered on the bank’s own secure payment page and are processed by the bank, with 3-D Secure authentication applied by Your card issuer. We receive confirmation of payment, the transaction amount and reference, and the billing details required to issue an invoice, but never Your full card number, expiry date or security code.
  • Website and course platform: the Service runs on Our own platform, operated by Us on Our own server infrastructure. Course videos and downloadable materials are currently delivered from that same infrastructure. If We begin using a third-party video hosting or content delivery provider, We will update this Privacy Policy accordingly.
  • Analytics: Google Analytics, provided by Google Ireland Limited.
  • Email delivery: emails are currently sent from Our own mail system. If We begin using a third-party email delivery platform, We will update this Privacy Policy and name that provider here.

Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, to understand how visitors find and use the Service. Google Analytics uses Cookies and similar identifiers to collect information such as the pages You view, how long You spend on them, the approximate location derived from Your IP address, the type of Device and browser You use, and the source that referred You to the Service.

This information is used in aggregate to measure and improve the Service. We have enabled IP anonymization where available, and We do not use Google Analytics to identify You personally or to combine analytics data with Your Account data.

Google Analytics Cookies are set only after You have given consent through the cookie banner on the Service, and You may withdraw that consent at any time. You can also opt out of Google Analytics across all websites by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

For information on how Google processes data, see Google’s Privacy Policy at https://policies.google.com/privacy and Google’s description of how it uses data from sites that use its services at https://policies.google.com/technologies/partner-sites.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Unless otherwise stated, the periods below are maximum periods, and We may delete or anonymize data sooner where it is no longer needed.

  • Account information and Course access records: retained for as long as Your Account remains open, and for up to 24 months after You close it or after Your last activity, in order to resolve disputes and enforce Our agreements. Because Courses are sold with lifetime access, closing Your Account will end Your access to purchased Courses.
  • Course progress data: retained for the life of Your Account.
  • Contact form messages and support correspondence: up to 24 months from the date the enquiry is closed.
  • Marketing data: retained until You unsubscribe, or up to 24 months from Your last engagement with Our emails, whichever comes first.
  • Usage Data and server logs: up to 24 months, for security monitoring, troubleshooting and analytics.
  • Transaction and invoice records: up to 10 years from the date of the transaction, to comply with tax and accounting obligations. Payment card details are not stored by Us at any time.

We may retain Personal Data beyond these periods where We are required to do so by law, where the data is necessary to establish, exercise or defend legal claims, or where residual copies remain in encrypted backups scheduled for routine deletion. When retention periods expire, We securely delete or anonymize the Personal Data.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. This means that Your information may be transferred to, and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction, where data protection laws may differ from those in Your jurisdiction.

Where required by applicable law, We ensure that international transfers of Your Personal Data are subject to appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, together with supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Your Privacy Rights

Depending on where You live, You may have some or all of the following rights in relation to Your Personal Data:

  • Right of access. To obtain confirmation of whether We process Your Personal Data and to receive a copy of it.
  • Right to rectification. To have inaccurate Personal Data corrected and incomplete Personal Data completed.
  • Right to erasure. To request deletion of Your Personal Data where there is no lawful reason for Us to continue processing it.
  • Right to restriction of processing. To request that We limit how We use Your Personal Data in certain circumstances.
  • Right to data portability. To receive the Personal Data You provided to Us in a structured, commonly used and machine-readable format, and to have it transmitted to another controller where technically feasible.
  • Right to object. To object to processing based on Our legitimate interests, and to object at any time to processing for direct marketing purposes.
  • Right to withdraw consent. Where processing is based on consent, to withdraw that consent at any time.
  • Right to lodge a complaint. To complain to the data protection supervisory authority in Your country of residence, place of work or place of the alleged infringement.

You may also update or correct much of Your information yourself by signing in to Your Account.

To exercise any of these rights, contact Us at the address in the “Contact Us” section below. We will respond within one month of receiving Your request; where a request is complex or where We receive a number of requests, We may extend this period by a further two months and will inform You if We do. Exercising these rights is free of charge, unless a request is manifestly unfounded or excessive. We may need to ask You for information to confirm Your identity before acting on a request. Please note that We may need to retain certain information where We have a legal obligation or other lawful basis to do so.

California Privacy Rights

If You are a resident of California, the California Online Privacy Protection Act (“CalOPPA”) gives You the right to know what Personal Information We collect, how We use it, and with whom We share it. That information is set out in this Privacy Policy.

  • Reviewing and changing Your information. You may review and change the Personal Information associated with Your Account at any time by signing in to Your Account, or by contacting Us at the address below.
  • Notice of changes. If We make material changes to this Privacy Policy, We will post the updated policy on this page and update the “Last updated” date at the top, and where appropriate We will notify You by email.
  • Do Not Track. Our response to DNT browser signals is described in the “Do Not Track Signals” section above.
  • Third-party tracking. We do not permit third parties to collect personally identifiable information about Your online activities over time and across different websites when You use Our Service.

Security of Your Personal Data

The security of Your Personal Data is important to Us. We use commercially reasonable technical and organizational measures to protect it, including encryption of data in transit, encrypted storage of passwords, and restricted access to systems containing Personal Data. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and We cannot guarantee its absolute security.

Children’s Privacy

Our Service is intended for adults. The Service does not address anyone under the age of 18, and We do not knowingly collect Personal Data from anyone under the age of 18. Purchasing a Course requires You to confirm that You are at least 18 years old.

If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18, We will take steps to remove that information from Our servers and to close the associated Account.

Links to Other Websites

Our Service contains links to other websites that are not operated by Us, including the websites of Our equipment partners referenced in discount offers inside the Courses. If You click on a third-party link, You will be directed to that third party’s site. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services. We strongly advise You to review the privacy policy of every site You visit.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date at the top. Where the changes are material, We will let You know by email and/or by a prominent notice on the Service before the change becomes effective.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any of Your privacy rights, You can contact us: