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Privacy Policy
Effective Date: October 6, 2025
Please read this Privacy Policy carefully and in its entirety before using this website or our software.
This Privacy Policy explains what information we collect, how it is used, and the measures we take to protect it across both our consulting and software operations.
Business Identity
This Site and related services are owned and operated by Willow Labs LLC, doing business as Holden Growth Consulting (“Holden Growth”) and Propel AI (“Propel AI”) (collectively, “Company,” “we,” or “us”).
This Privacy Policy applies to:
Consulting, strategy, advisory, and marketing services offered under Holden Growth Consulting; and
The Propel AI software platform and any associated web or hosted applications.
If you have questions about this Privacy Policy, please contact us at [email protected].
If you do not agree with the terms of this Privacy Policy, please do not use our Site or Services.
1. Information We Collect
Information You Provide Directly
Name, email address, billing address, payment information.
Submitted forms, comments, or communications.
Information needed to process purchases or deliver services.
Information Collected Automatically
Device type, browser, IP address, geographic location, and pages visited.
Analytics data about how you interact with our Site or Software (e.g., page views, usage time, features accessed).
Information collected via cookies and tracking technologies (see Section 4).
Information Collected Through Propel AI Software
When you or your end users use the Propel AI platform, we may process:
Account registration information (e.g., user name, email, business details).
Customer Data you upload or enter (e.g., leads, contacts, form submissions, messages).
Usage logs, device identifiers, and event data necessary to operate and secure the platform.
We process Customer Data as a data processor on your behalf. You remain the data controller for all Customer Data entered into the Software.
1. How We Use Your Information
We may use collected information to:
Deliver products, services, and requested information.
Configure and maintain user accounts within the Propel AI platform.
Improve the Site, Software, and user experience.
Respond to inquiries or customer support requests.
Send updates, educational content, or promotions (with opt-out options).
Process payments and transactions.
Personalize content and advertising.
Ensure security, prevent fraud, and comply with applicable law.
3. Data Retention
We retain your Personal Information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law (such as tax, accounting, or legal obligations).
Transaction records: 7 years (tax/accounting purposes).
Client files and communications: typically 3–7 years.
Marketing and email data: Until you unsubscribe or request deletion.
Analytics data: Up to 26 months.
Customer Data in Propel AI: While your account is active + 30 days after termination
General inquiries: 1–2 years.
After these periods, we securely delete or anonymize your information.
4. Cookies, Pixels, and Tracking
We use cookies, pixels, and similar technologies (including analytics and ad tools) to:
Understand how visitors use our Site and Software.
Improve performance, navigation, and functionality.
Deliver relevant ads and measure campaign effectiveness.
You can control cookies through your browser settings; disabling them may affect certain features. By continuing to use our Site or Software, you consent to our use of these technologies.
5. Sharing Your Information
We do not sell your Personal Information. We share it only as reasonably necessary to operate and improve our Services:
Service Providers – e.g., payment processors, analytics, CRM, or hosting partners (such as GoHighLevel, Twilio, Mailgun, Google Analytics) who act as processors under written contracts that restrict use of your data.
Business Operations – affiliates, successors, or service providers in connection with a business transaction or reorganization.
Legal Requirements – when required by law, subpoena, or government authority.
Aggregated / De-identified Data – for marketing or analytics, never identifying individuals.
We require our service providers to handle data securely and only in accordance with our instructions.
6. Security
We use commercially reasonable safeguards to protect your information, including:
Secure servers and encryption (HTTPS/SSL)
Access control and employee confidentiality obligations
Routine data backups and monitoring
Payment information is processed by secure third-party processors and is not stored on our servers.
If we become aware of a data breach likely to affect your rights or freedoms, we will notify you promptly in accordance with applicable law.
7. Third-Party Links
Our Site and Software may contain links to third-party websites or embedded content. We are not responsible for the privacy practices of those third parties. Please review their policies before providing any personal information.
8. Your Rights
Depending on your location, you may have rights regarding your Personal Information.
GDPR (EU/EEA)
You may request access, correction, or deletion of your Personal Information, and object to or restrict certain processing. We process data on legitimate interests, contract performance, or consent, as applicable.
CCPA/CPRA (California Residents)
You have the right to:
Know what categories of Personal Information we collect and how we use it.
Request access to and deletion of your Personal Information.
Opt-out of the “sale” or “sharing” of Personal Information (we do not sell data).
Not be discriminated against for exercising your rights.
We will respond to verified CCPA/CPRA requests within 45 days, unless an extension is permitted by law.
To exercise any of these rights, contact us at [email protected].
9. Children's Privacy
Our Site and Software are not intended for children under 13 (U.S.) or 16 (EU). We do not knowingly collect information from children. If you believe your child has provided data to us, please contact us for deletion.
10. Email Marketing (CAN-SPAM Compliance)
We collect your name and email address to:
Send requested content or transactional updates.
Provide newsletters and promotional communications.
You may unsubscribe at any time by clicking “Unsubscribe” in emails or contacting us directly. We will promptly remove you from future communications.
11. International Data Transfers
Your information may be processed or stored on servers located outside your state or country (including the United States), where data protection laws may differ. We maintain appropriate safeguards consistent with applicable law for such transfers.
12. Changes to This Policy
We may update this Privacy Policy periodically. The “Effective Date” above reflects the most recent revision. Continued use of our Site or Services after updates constitutes acceptance of the revised Policy.
Contact Us
Willow Labs LLC d/b/a Holden Growth Consulting and Propel AI
Email: [email protected]
Mailing Address: 3000 Village Run Road #103-353, Wexford, PA 15090
Last Updated: October 6, 2025
