Privacy notice

Last updated: 6 August 2026.

Who is responsible

Growth Path Agency S.R.L. ("Growth Path", "we", "us") is the controller of personal data processed through this website, bisceanu.com, the personal site of Vlad Bisceanu, fractional CMO for technical B2B companies, founder of Growth Path AI.

Registered office: Str. Drumul Putnei nr. 38-42, Et. 4, Ap. 33, Sector 3, Bucuresti, Romania. Trade Registry: J2025042918007 (Oficiul Registrului Comertului de pe langa Tribunalul Bucuresti). Unique Registration Code (CUI): RO51980049.

Privacy contact: privacy@growthpath.systems.

What we collect, and why

Server and hosting logs. Our hosting provider (Cloudflare) records technical metadata when you load a page: IP address, user-agent string, timestamps, and response status. These logs help us investigate errors and detect abuse.

Aggregate site analytics. We use Plausible Analytics to count page views. Plausible does not set cookies and does not store personal identifiers. It counts unique visitors with a daily-rotating, salted hash of IP plus user-agent, and discards the hash within 24 hours. You cannot be identified or tracked across sites.

Contact form. When you submit the form, we collect the name, email address, and message you provide so we can reply. The submission passes a Cloudflare Turnstile spam check and is delivered to our mailbox through Loops, our email platform. You join our marketing audience only if you tick the optional marketing checkbox; otherwise you are not on any marketing list.

Error reports. We use Sentry to monitor technical errors. An error report can include your IP address and technical context about the failure.

Legal bases

Hosting logs, analytics aggregates, and error monitoring run on Art. 6(1)(f) GDPR: our legitimate interest in operating a working, abuse-free site. Contact-form processing runs on Art. 6(1)(b): steps taken at your request prior to entering a contract. Occasional marketing messages run on Art. 6(1)(a): the consent you give by ticking the optional marketing checkbox, withdrawable any time via the unsubscribe link in any message or the privacy contact above.

Processors and recipients

We share personal data with a short list of processors that run the site:

Cloudflare, Inc.: hosting, DNS, and Turnstile spam protection. Primary edge in EU regions. DPA

Plausible Insights OU: cookieless analytics, hosted in Germany. Aggregates only. Privacy policy

Loops (Astrodon Corp.): delivery of contact-form submissions. US-based. DPA

Functional Software, Inc. (Sentry): error monitoring, EU data residency. DPA

International transfers

Loops is a US company; sending your email there is a transfer under Chapter V GDPR, covered by the Standard Contractual Clauses in Loops' Data Processing Agreement. Cloudflare serves traffic primarily from EU/EEA regions; where a workload touches a non-EU point of presence, Cloudflare's SCCs apply. You can request a copy of the relevant safeguards at the privacy contact above.

Retention

Contact-form correspondence is retained for up to 36 months after the last exchange. Hosting logs are short-lived operational data. Plausible aggregates contain no personal identifiers and are retained indefinitely.

Your rights

You can request access, rectification, erasure, restriction, portability, or object to processing based on legitimate interest. Email privacy@growthpath.systems; we respond within 30 days (Art. 12(3) GDPR). You can also complain to the Romanian supervisory authority (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 Bucuresti, Romania.

Cookies

This site stores nothing non-essential on your device, so no consent banner is required (Art. 5(3) of Directive 2002/58/EC, transposed by Legea 506/2004). Cloudflare Turnstile may set a short-lived challenge cookie during form submission if it presents an anti-bot challenge; that cookie is strictly necessary spam defense, not analytics or advertising.

Other things worth knowing

We have not appointed a Data Protection Officer; our processing does not meet the thresholds in Art. 37 GDPR or Law 190/2018. This is a B2B site: we do not process special-category data, we do not collect the Romanian CNP, and we do not knowingly collect data from anyone under 16. When this notice changes, we update this page and the date at the top.

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