Privacy Policy

Last Updated: May 20, 2026

1. Introduction

THE SNOWBALL OF GROWTH S.R.L. ("Company", "we", "us", or "our"), operating under the brand The Digital Leverage Lab, respects your privacy and is strictly committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (www.thedigitalleveragelab.com), utilize our white-labeled software platform, courses, and community features, and tell you about your privacy rights and how the law protects you.

We comply with the General Data Protection Regulation (GDPR) (EU) 2016/679 and relevant Romanian legislation regarding data protection.

2. Who We Are (Data Controller)

The entity responsible for your personal data (Data Controller) is:

  • Company Name: THE SNOWBALL OF GROWTH S.R.L.

  • Fiscal Registration Code (CUI): 53182345

  • European Unique Identifier (EUID): ROONRC.J2025100465009

  • Registered Office (Sediu Social): București Sectorul 3, Aleea EPRUBETEI, Nr. 25C, CAMERA 1, Etaj 8, Ap. 64.

  • Email Address: support@thedigitalleveragelab.com

3. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: First name, last name.

  • Contact Data: Email address, billing address (required for invoicing upon purchase of subscriptions or services).

  • Transaction Data: Details about payments to and from you, and details of subscriptions and products you have purchased from us. Note: We do not store your Credit Card information directly. Payments are processed securely via Stripe.

  • Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform.

  • Usage Data: Information about how you use our website, white-labeled software features, courses, and community forums.

  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties.

4. How We Collect Your Data

  • Direct Interactions: You may give us your Identity and Contact Data by filling in forms to access our free mini-course, creating a free software account, subscribing to our $69/month premium tier, or by corresponding with us via email.

  • Automated Technologies: As you interact with our website, we use CookieYes as our consent management platform to automatically collect Technical Data about your equipment, browsing actions, and patterns via cookies and pixels (e.g., Facebook/Meta Pixel, Google Analytics, and TikTok Pixel).

5. How We Use Your Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. Performance of Contract: To provision your free or paid account, deliver course curriculums, grant community access, and provide the underlying digital marketing platform services.

  2. Legitimate Interest: To provide first-level technical support, prevent fraud, troubleshoot account issues, and analyze user behavior to improve our software and educational offerings.

  3. Legal Obligation: To keep accounting records and issue invoices as required by Romanian Tax Law (ANAF).

  4. Consent: To send you email marketing, newsletters, and promotional campaigns regarding our business. You may withdraw consent at any time by clicking "Unsubscribe" at the bottom of our emails.

6. Disclosures of Your Data (Third Parties)

We do not sell your personal data. Because our platform is a white-labeled service, we share necessary data with trusted Data Processors who help us run our business and provide the software functionality to you:

  • Systeme.io (Platform Provider): We operate as an authorized reseller. Systeme.io acts as our core IT processor, securely hosting the website, the user dashboards, the courses, the community, and facilitating email delivery.

  • Stripe (Payment Processor): Connected via Systeme.io to securely process your monthly subscription payments and facilitate refunds.

  • Google, Meta (Facebook/Instagram), & TikTok: We use tracking pixels for advertising analytics and retargeting (showing you relevant ads based on your site visits).

  • CookieYes: Used to manage and store your cookie consent preferences.

  • Romanian Authorities: We may disclose data to ANAF (National Agency for Fiscal Administration) if legally required for financial compliance and audits.

7. International Transfers

Some of our external third parties (such as Systeme.io or Stripe) may be based, or have servers located, outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by utilizing specific contracts approved by the European Commission (Standard Contractual Clauses) or by ensuring the providers are certified under the EU-US Data Privacy Framework.

8. Data Retention

  • Platform & Marketing Data: We retain your account data and email address as long as your account is active or until you unsubscribe from our communications.

  • Transaction Data: By Romanian law, we are required to keep basic information about our customers (including Contact, Identity, and Transaction Data) for accounting and tax purposes for 10 years after they cease being customers.

9. Your Legal Rights

Under the GDPR, you have the following rights concerning your personal data:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data ("Right to be forgotten").

  • Object to processing of your personal data.

  • Request restriction of processing.

  • Request transfer of your personal data to you or a third party.

  • Right to withdraw consent at any time.

To exercise any of these rights, please contact us at support@thedigitalleveragelab.com. We aim to respond to all legitimate requests within 30 days.

10. Advertising and Retargeting

We actively use third-party advertising services (such as Facebook Ads and Google Ads) to promote our brand. These networks use cookies and pixels to track your activity on our website to display relevant advertisements to you across the internet (Retargeting). By engaging with our CookieYes consent banner and accepting our Cookie Policy, you consent to this tracking mechanism.

11. Complaints

You have the right to make a complaint at any time to the Romanian supervisory authority for data protection issues:
ANSPDCP (Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal) - www.dataprotection.ro.