Legal

Privacy Policy

Effective date: 18 March 2026 · Last updated: 18 March 2026

GrowThrough Coaching (Pty) Ltd, trading as Clinton Middleton ("we", "us", or "our"), operates the website clintonmiddleton.co.za. We are committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) and applicable data protection principles.

This policy explains what personal information we collect, why we collect it, how we use it, and what rights you have in relation to it.

1. Who We Are

GrowThrough Coaching (Pty) Ltd is the responsible party under POPIA for personal information collected through this website. You can contact us at:

• Email: clinton@growthrough.co
• Website: clintonmiddleton.co.za

2. What Information We Collect

We collect personal information in the following ways:

• Calendly bookings: When you book a discovery call or coaching session, Calendly collects your name, email address, phone number, and any information you provide in the booking form.
• Email marketing: If you subscribe to our mailing list, Kit (ConvertKit) collects your name and email address.
• Website analytics: Google Analytics (GA4) collects anonymised data about how visitors use this website, including pages visited, time spent, and general location data. This data does not identify you personally.
• Advertising tracking: Meta Pixel collects data about your visit to this website to help us measure the effectiveness of our advertising on Facebook and Instagram.

3. Why We Collect Your Information

We use your personal information for the following purposes:

• To schedule and manage coaching sessions and discovery calls
• To send you information about our coaching services if you have opted in
• To improve our website and understand how visitors use it
• To measure the effectiveness of our advertising campaigns
• To comply with our legal obligations

4. Legal Basis for Processing

We process your personal information on the following grounds:

• Consent: Where you have given us permission to contact you or use your data for marketing purposes.
• Contractual necessity: Where processing is necessary to provide coaching services you have requested.
• Legitimate interest: Where we have a legitimate business interest, such as improving our website and measuring advertising effectiveness.

5. Third-Party Services

We use the following third-party services that may collect or process your personal information:

• Calendly — scheduling and booking. View their privacy policy.
• Kit (ConvertKit) — email marketing. View their privacy policy.
• Google Analytics (GA4) — website analytics. View Google's privacy policy.
• Meta Pixel — advertising measurement. View Meta's privacy policy.

These services have their own privacy policies and data processing practices. We encourage you to review them.

6. Cookies

This website uses cookies and similar tracking technologies. Please refer to our Cookie Policy for full details on what cookies we use and how to manage them.

7. How Long We Keep Your Information

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Coaching session records are retained for a period of three years after the conclusion of a coaching engagement. Marketing data is retained until you unsubscribe or request deletion.

8. Your Rights Under POPIA

As a data subject under POPIA, you have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information, subject to legal obligations
• Object to the processing of your personal information
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Information Regulator of South Africa

To exercise any of these rights, please contact us at clinton@growthrough.co. We will respond within 30 days.

9. Information Regulator

You have the right to lodge a complaint with the Information Regulator of South Africa if you believe your personal information has been processed in violation of POPIA:

• Website: inforegulator.org.za
• Email: inforeg@justice.gov.za

10. Security

We take reasonable technical and organisational measures to protect your personal information from unauthorised access, loss, or misuse. However, no method of transmission over the internet is completely secure and we cannot guarantee absolute security.

11. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of significant changes by updating the effective date at the top of this page. We encourage you to review this policy periodically.

12. Contact Us

If you have any questions about this privacy policy or how we handle your personal information, please contact us at clinton@growthrough.co.