Legal
Privacy Policy
Last updated Thursday, September 10, 2026
Contents
00
Privacy at a Glance
01
Who We Are and What This Policy Covers
02
Personal Information We Collect
03
How We Use Personal Information
04
Legal Bases for Processing (European Economic Area, United Kingdom, and Switzerland)
05
Cookies and Similar Technologies
06
Google Analytics: Detailed Disclosure
07
How We Share Personal Information
08
Third-Party Websites and Services
09
How Long We Keep Personal Information
10
How We Protect Personal Information
11
Your Privacy Rights and How to Exercise Them
12
Additional Disclosures for United States Residents
13
International Users
14
Children’s Privacy
15
Marketing Communications and Opt-Out
16
Business Transfers
17
Changes to This Policy
18
Contact Us
00
Privacy at a Glance
This summary is provided for convenience and is not a substitute for the full Policy below.
We collect very little. The only forms on this website are the seat reservation forms on event pages, which ask for your full name, your email address, and the number of closings you have completed in the last 12 months. There are no user accounts and no checkout. Beyond those forms, the only information collected on the website itself is technical usage data from Google Analytics 4 (and only if you accept analytics cookies in our cookie banner) and standard hosting logs.
If you book a consultation, you do so on Calendly, and we receive the details you enter there (your name, email address, and any answers to booking questions).
We use your information to run the website, to reserve your seat at events, to schedule and hold consultations, to provide coaching if you become a client, and, with your permission, to tell you about our coaching, workshops, and events.
We do not sell your personal information, do not share it for targeted advertising, and do not use it to make automated decisions that have legal effects on you.
You can ask to access, correct, or delete your information, or opt out of marketing, at any time by emailing tom@martinmartinhomes.com. We honor these requests for everyone, regardless of where you live.
01
Who We Are and What This Policy Covers
This Privacy Policy (“Policy”) explains how Growth Through Others (“GTO,” “we,” “us,” or “our”), a real estate coaching and training business owned and operated by Thomas (“Tom”) Martin, an individual doing business as Growth Through Others, with a principal business address at 132 W International Speedway Blvd, Daytona Beach, FL 32114, United States, collects, uses, shares, and protects personal information when you:
visit growththroughothers.com (the “Site”);
book or attend a consultation;
communicate with us by email, phone, text message, or social media;
engage GTO for coaching, workshops, or events; or
otherwise interact with us.
For purposes of the European Union and United Kingdom General Data Protection Regulation, GTO is the “controller” of your personal information. For purposes of United States state privacy laws, GTO is the “controller” or “business.”
This Policy does not cover the practices of third-party services we link to, such as Calendly, YouTube, Instagram, Facebook, or event ticketing platforms, each of which has its own privacy policy. This Policy also does not cover Tom Martin’s separate real estate brokerage activities, which are conducted through a separate brokerage with its own privacy practices.
“Personal information” means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to you. It does not include de-identified or aggregated information.
02
Personal Information We Collect
2.1 Information you provide to us
Consultation bookings (through Calendly). When you schedule a consultation through a Calendly link on the Site, Calendly collects and shares with us the information you enter: your name, email address, the date and time you select, your time zone, and, if requested in the booking form, your phone number and answers to booking questions (for example, your market, brokerage, years in real estate, or what you want to work on). Calendly also processes this information under its own privacy policy.
Direct communications. When you email, call, text, or message us on social media, we collect your contact details, the content of your message, and any information you choose to include.
Consultations and coaching. During a consultation or coaching engagement, you may share information about your business, production, goals, challenges, team, and finances. We keep notes of these conversations. If a session is recorded with your consent (as described in our Terms and Conditions), we retain the recording.
Coaching clients. If you become a client, we collect the information needed to deliver and administer services and to invoice you, which may include your mailing address and billing information. Payments are processed through third-party payment or invoicing services, and we do not store full payment card numbers.
Testimonials. If you provide a testimonial, we collect your name, business or market, photograph (if provided), and your statement, along with your written permission to use them.
Event seat reservations (through forms on the Site). When you reserve a seat at an event using a form on the Site, we collect your full name, your email address, the number of closings you have completed in the last 12 months, your acceptance of our Terms and Conditions and this Policy, whether you checked the optional box to receive coaching emails from Tom Martin, the event you reserved, and the date and time of your submission. Form submissions are transmitted through Zapier, an automation service, to our email marketing platform and other business tools, as described in Section 7.
Events registered through other platforms. If an event uses a third-party registration or ticketing platform (for example, Eventbrite, Zoom, or a similar service), that platform collects your registration information and shares it with us, typically including your name, email address, phone number, ticket type, and payment status (but not card details). If you ask a question or otherwise participate in a session, your participation may be recorded.
Email subscriptions. If you check the optional box on an event reservation form to receive coaching emails from Tom Martin, if you otherwise subscribe to our emails, or if you have booked a consultation or become a client and have not opted out, we keep your email address, a record of your consent (including the date and the form used), and engagement data (such as opens and clicks) provided by our email service.
2.2 Information collected automatically
Google Analytics 4. If you accept analytics cookies in our cookie banner, we use Google Analytics 4 (“GA4”) to understand how visitors use the Site. GA4 collects: pages viewed, time on page, referring website or source, approximate location at the city or region level (derived from your IP address, which GA4 does not log or store), device type, operating system, browser, screen resolution, language, and interactions such as clicks on the “schedule a consultation” link, video plays, and form submissions (GA4 records that a form was submitted, not what you entered in it). GA4 assigns a random client identifier, stored in a cookie, to distinguish visitors and sessions. See Sections 5 and 6 for more detail.
Hosting and security logs. Our hosting provider, Framer, automatically records standard technical information when you visit the Site, such as your IP address, browser type, pages requested, date and time of access, and referring URL, for security, performance, and fraud prevention. Framer may also provide us with aggregated, cookie-free site statistics.
Cookie preferences. We store your cookie banner choice so that we do not ask you again on every visit.
2.3 Information from other sources
Calendly, event platforms, and email services, as described above.
Social media platforms, when you interact with our accounts, subject to your settings on those platforms.
Referrals, when someone you know introduces you to us and shares your name and contact information.
Publicly available sources, such as your brokerage website or professional profile, which we may review before a consultation in order to prepare.
2.4 Information we do not collect through the Site
Other than the event reservation forms described above, the Site has no contact forms, sign-up forms, comment sections, user accounts, chat widgets, or checkout. We do not collect through the Site: payment information; government identification numbers; precise geolocation; biometric information; health information; or information about your racial or ethnic origin, religious beliefs, sexual orientation, citizenship or immigration status, or union membership. We do not knowingly collect any of this “sensitive” information anywhere in our business unless you volunteer it, and we ask that you not share it with us.
03
How We Use Personal Information
We use personal information for the following purposes:
to respond to your inquiry and to schedule, confirm, remind you about, reschedule, and conduct consultations;
to process event seat reservations, manage capacity, confirm your seat, send event details, reminders, and updates, and tailor event content to the experience level of attendees;
to evaluate whether coaching is a fit and to prepare for consultations;
to provide, administer, and improve coaching, workshops, and events, and to keep records of sessions;
to invoice and collect payment from clients and to maintain business and tax records;
to send you information about our coaching, workshops, events, videos, and other content that we think will interest you, subject to your right to opt out (see Section 15);
to send administrative notices, such as changes to our Terms and Conditions or this Policy;
to operate, secure, analyze, and improve the Site, including understanding which content is useful and where visitors come from;
to display testimonials with your permission;
to comply with legal obligations, respond to lawful requests, enforce our Terms and Conditions, and protect our rights, property, and safety and those of others;
to detect, prevent, and address fraud, abuse, security incidents, and technical problems;
in connection with a sale, merger, or reorganization of our business (see Section 16); and
for any other purpose we describe at the time we collect the information, or with your consent.
We do not use personal information for automated decision-making or profiling that produces legal or similarly significant effects on you.
04
Legal Bases for Processing (European Economic Area, United Kingdom, and Switzerland)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases:
Consent (Article 6(1)(a) GDPR): analytics cookies; coaching emails you opt into on an event reservation form; other marketing emails where consent is required; testimonials; recordings.
Performance of a contract, or steps taken at your request before entering into one (Article 6(1)(b) GDPR): reserving and confirming event seats; scheduling and conducting consultations; providing coaching under a Coaching Agreement.
Legal obligation (Article 6(1)(c) GDPR): tax, accounting, and legal record-keeping; responding to lawful requests.
Legitimate interests (Article 6(1)(f) GDPR): securing and improving the Site; preventing fraud; communicating with existing clients about related services; maintaining business records; enforcing our Terms and Conditions. We balance these interests against your rights and freedoms and do not rely on this basis where your interests override ours.
You may withdraw consent at any time (see Section 11). Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
05
Cookies and Similar Technologies
5.1 What we use
Cookie or technology
Set by
Purpose
Type
Duration
Cookie consent preference
GTO (cookie banner)
Remembers whether you accepted or declined analytics cookies
Strictly necessary
Up to 12 months
_ga
Google Analytics
Distinguishes visitors using a random client identifier
Analytics (consent required)
2 years
_ga_[container ID]
Google Analytics
Maintains session state for GA4
Analytics (consent required)
2 years
Embedded video cookies
YouTube (Google)
Set only if you play an embedded video; used by YouTube for playback and for its own purposes
Third-party
Varies; see Google’s privacy policy
Our hosting provider may also set strictly necessary technical cookies or use local storage needed to deliver the Site securely.
5.2 Cookie banner and your choices
When you first visit the Site, a cookie banner asks whether you accept analytics cookies. Analytics cookies are not set unless you accept. You can change your choice at any time by using the cookie settings link in the Site footer, by clearing your browser cookies (which will cause the banner to appear again), or by using the browser controls described below. Declining analytics cookies does not affect your ability to use the Site.
5.3 Other ways to control cookies and tracking
Browser settings. Most browsers let you block or delete cookies. Consult your browser’s help pages. Blocking all cookies may affect some website features.
Google Analytics opt-out browser add-on. Available at https://tools.google.com/dlpage/gaoptout, this add-on prevents GA4 from collecting data on any website you visit.
Global Privacy Control. We do not sell or share personal information, so there is no sale or sharing to opt out of through a Global Privacy Control (GPC) signal. Where our cookie banner can detect a GPC signal, we treat it as declining analytics cookies.
Do Not Track. We do not currently respond to “Do Not Track” browser signals because there is no common industry standard for interpreting them. This disclosure is made in accordance with the California Online Privacy Protection Act.
06
Google Analytics: Detailed Disclosure
The Site uses Google Analytics 4, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google processes analytics data on our behalf as our service provider and processor.
How it works. GA4 uses first-party cookies (listed in Section 5.1) and JavaScript to collect information about how you use the Site. That information is transmitted to and stored by Google on its servers, including servers in the United States. Google uses it to compile reports for us on Site activity and to provide other services relating to Site usage.
Our configuration. We have configured GA4 as follows: Google Signals is turned off; advertising features, remarketing, and demographics and interests reporting are turned off; we do not use the User-ID feature or send personally identifiable information (such as names or email addresses) to Google Analytics; and user-level and event-level data retention is set to 14 months, after which that data is automatically deleted from Google’s servers (aggregated reports are retained).
IP addresses. GA4 does not log or store IP addresses. Google uses IP address metadata to derive an approximate location (city or region) and then discards the IP address.
How Google uses data. You can learn how Google uses information from sites or apps that use its services at https://policies.google.com/technologies/partner-sites, and you can read Google’s privacy policy at https://policies.google.com/privacy.
International transfers. Google LLC is certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, and also offers Standard Contractual Clauses for transfers of analytics data.
Opting out. Decline analytics cookies in our cookie banner, install the opt-out add-on linked above, or block cookies in your browser.
07
How We Share Personal Information
We do not sell personal information, and we have not sold personal information in the preceding 12 months. We do not “share” personal information for cross-context behavioral advertising, and we do not process it for targeted advertising, as those terms are defined in United States state privacy laws. We share personal information only as follows:
Service providers and processors. Companies that perform services for us under contracts that limit their use of your information to providing those services, including: scheduling (Calendly); website hosting and content delivery (Framer); form processing and workflow automation (Zapier), which receives event reservation submissions from the Site and routes them to our email marketing platform and other business tools; web analytics (Google Analytics); business email and calendar (Google Workspace or a similar provider); email marketing and list management (currently Mailchimp, an Intuit company); video conferencing (Zoom or a similar provider) for virtual consultations and sessions; event registration and ticketing (Eventbrite or a similar provider); payment processing and invoicing for clients; document and file storage; and cookie consent management.
Professional advisers. Attorneys, accountants, bookkeepers, and insurers, under confidentiality obligations, to the extent needed to run our business.
Legal, safety, and enforcement. When we believe disclosure is required by law, subpoena, court order, or governmental request; to enforce our Terms and Conditions or a Coaching Agreement; to protect the rights, property, or safety of GTO, our clients, or the public; or to detect or address fraud or security issues.
Business transfers. As described in Section 16.
With your consent or at your direction. For example, when you ask us to introduce you to someone, or when you give permission for a testimonial.
We do not share personal information with Tom Martin’s real estate brokerage for brokerage purposes.
08
Third-Party Websites and Services
The Site links to, and may embed content from, third parties, including Calendly, YouTube, Instagram, Facebook, and event platforms. When you click a link, play an embedded video, or use one of these services, that third party may collect information about you under its own privacy policy, which we encourage you to read:
Calendly: https://calendly.com/privacy
Google and YouTube: https://policies.google.com/privacy
Framer: https://www.framer.com/legal/privacy-statement/
Mailchimp (Intuit): https://mailchimp.com/legal/privacy/
Meta (Instagram and Facebook): https://www.facebook.com/privacy/policy/
Zapier: https://zapier.com/privacy
We are not responsible for the privacy practices of third parties.
09
How Long We Keep Personal Information
We keep personal information only as long as needed for the purposes described in this Policy, and then delete or de-identify it, unless a longer period is required or permitted by law. Our general retention periods are:
Consultation bookings and prospect communications: up to 3 years after our last meaningful contact with you, so that we can follow up and answer questions about prior conversations.
Event reservation records: up to 3 years after the event, so that we can answer questions about attendance and, if you opted in, invite you to similar events.
Coaching client records, including Coaching Agreements, session notes, and invoices: the duration of the engagement plus 7 years, to satisfy tax, accounting, and legal record-keeping requirements and to defend against claims.
Recordings of sessions: up to 2 years, unless you ask us to delete them sooner or a longer period is needed for a legal reason.
Marketing email list: until you unsubscribe or your address becomes inactive. After you unsubscribe, we keep your email address on a suppression list indefinitely so that we do not email you again.
Testimonials: for as long as we display them, plus 3 years after you withdraw permission, for our records.
Google Analytics data: 14 months at the user and event level (see Section 6).
Hosting and security logs: as retained by our hosting provider, typically 30 to 90 days.
Cookie consent record: up to 12 months.
Legal and dispute records: for the duration of the matter plus the applicable limitations period.
10
How We Protect Personal Information
We use reasonable administrative, technical, and physical safeguards appropriate to the size of our business and the sensitivity of the information, including: using reputable service providers with strong security programs; encrypting data in transit (the Site is served over HTTPS); limiting access to personal information to those who need it; using multi-factor authentication on business accounts; and keeping systems updated. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
If a security breach affects your personal information, we will notify you and the appropriate authorities as required by the Florida Information Protection Act of 2014 (Section 501.171, Florida Statutes) and other applicable breach notification laws. In Florida, this generally requires notice to affected individuals within 30 days after we determine that a breach has occurred.
11
Your Privacy Rights and How to Exercise Them
We extend the following rights to everyone whose personal information we hold, regardless of where you live, even where the law may not require us to do so:
Access: request confirmation that we process your personal information and receive a copy of it.
Correction: request that we correct inaccurate or incomplete personal information.
Deletion: request that we delete your personal information, subject to exceptions (for example, records we must keep for legal or accounting reasons, or information needed to complete a service you requested).
Portability: receive the personal information you provided to us in a portable, machine-readable format.
Opt out of marketing: unsubscribe from marketing emails or texts at any time.
Withdraw consent: withdraw any consent you have given (for example, to analytics cookies, recordings, or testimonials).
Restrict or object: object to processing based on legitimate interests, or ask us to restrict processing, in the circumstances provided by applicable law.
Opt out of sale, sharing, targeted advertising, and profiling: we do not engage in these activities, so there is nothing to opt out of, but you may confirm this with us at any time.
Non-discrimination: we will not deny services, charge different prices, or provide a different level of service because you exercised your rights.
Appeal: if we deny your request, you may appeal, as described below.
How to submit a request. Email tom@martinmartinhomes.com with the subject line “Privacy Request,” or write to Growth Through Others, Attn: Privacy, 132 W International Speedway Blvd, Daytona Beach, FL 32114, United States. Tell us which right you are exercising and how to reach you. You may also call (407) 921-3645.
Verification. To protect your information, we will verify your identity before acting on a request, usually by confirming that the request comes from the email address we have on file or by asking you to confirm details about your interactions with us. We use the information you provide for verification only for that purpose.
Authorized agents. You may designate an authorized agent to make a request on your behalf. We will require proof of the agent’s authority (such as signed permission) and may still verify your identity directly with you.
Timing and cost. We will respond within 45 days after receiving a verifiable request. We may extend that period by another 45 days when reasonably necessary, in which case we will tell you. Requests are free, except that we may charge a reasonable fee for, or decline to act on, requests that are manifestly unfounded, excessive, or repetitive (more than two requests in a 12-month period), as permitted by law.
Appeals. If we decline all or part of your request, we will explain why. You may appeal within 60 days by replying to our decision with the subject line “Privacy Appeal.” We will respond to appeals within 45 days. If your appeal is denied, you may contact your state attorney general (or the data protection authority in your country) using the contact information we will provide with our response.
12
Additional Disclosures for United States Residents
12.1 All United States residents
Twenty states, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, have enacted comprehensive privacy laws, and additional laws take effect in 2027 and beyond. Most of these laws apply only to businesses that process the personal information of tens of thousands of residents or that meet revenue thresholds. GTO is a small business that may not meet those thresholds. Regardless, we voluntarily honor the rights described in Section 11 for residents of every state, and we follow these laws’ core principles: we tell you what we collect and why, we collect only what we need, we do not sell or share your information for advertising, we do not process sensitive information without consent, and we provide a way for you to exercise your rights and to appeal our decisions.
12.2 California residents (CCPA/CPRA and CalOPPA)
This Section supplements the rest of this Policy for California residents and serves as our “notice at collection.” GTO may not qualify as a “business” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), but we provide these disclosures and honor these rights voluntarily.
Categories of personal information collected in the preceding 12 months, with sources, purposes, and recipients:
Category (Cal. Civ. Code 1798.140)
Examples we collect
Source
Purposes
Disclosed to
Identifiers
Name, email address, phone number, IP address (hosting logs only), online identifier (GA4 client ID)
You (through event reservation forms on the Site, Calendly, email, or events); collected automatically
Event reservations, scheduling, communications, marketing, Site operation, security
Scheduling, hosting, analytics, automation (Zapier), email, event, and conferencing service providers
Customer records (Cal. Civ. Code 1798.80(e))
Name, contact details, and billing information for clients
You
Providing and invoicing services
Payment, invoicing, and accounting providers
Commercial information
Consultations booked, events reserved or attended, services purchased, engagement with our emails, coaching email opt-in status
You; our records; our email provider
Providing services, follow-up, marketing
Automation (Zapier), email, and event service providers
Internet or other electronic network activity
Pages viewed, referring site, clicks, device and browser information
Collected automatically (GA4, hosting logs)
Site analytics, security
Google Analytics, Framer
Geolocation data (approximate only)
City or region derived from IP address
Collected automatically (GA4)
Site analytics
Google Analytics
Professional or employment-related information
Number of closings in the last 12 months, brokerage, role, years in real estate, production, team size, goals
You (through event reservation forms and in sessions)
Planning and tailoring events, evaluating fit, preparing for and delivering coaching
Automation (Zapier), email, conferencing, and document storage providers
Audio, electronic, or visual information
Recordings of sessions or events (with consent); photographs and testimonials (with permission)
You
Coaching records, content, testimonials
Storage and conferencing providers; the public (testimonials only, with your permission)
Inferences
Limited inferences about your coaching needs drawn from what you tell us
Derived by us
Tailoring coaching
Not disclosed
Categories not collected: characteristics of protected classifications under California or federal law; biometric information; precise geolocation; education information; and sensitive personal information (except any that you volunteer during a session, which we do not use to infer characteristics about you).
Sale and sharing. We do not sell personal information or share it for cross-context behavioral advertising, and we have not done so in the preceding 12 months. We have no actual knowledge that we sell or share the personal information of consumers under 16 years of age.
Sensitive personal information. We do not collect sensitive personal information for the purpose of inferring characteristics about you, and we do not use or disclose any sensitive personal information beyond the purposes permitted by Section 7027(m) of the CCPA regulations.
Your California rights. In addition to the rights in Section 11 (the rights to know, delete, correct, and receive portable data, and the right to non-discrimination), you have the right to opt out of the sale or sharing of personal information (not applicable, since we do not sell or share) and the right to limit the use of sensitive personal information (not applicable, since we do not use it beyond permitted purposes). Exercise your rights as described in Section 11.
Financial incentives. We do not offer financial incentives, or price or service differences, in exchange for personal information.
“Shine the Light” (Cal. Civ. Code 1798.83). We do not disclose personal information to third parties for their own direct marketing purposes.
Do Not Track. See Section 5.3.
12.3 Florida residents
The Florida Digital Bill of Rights (Sections 501.701 through 501.722, Florida Statutes) imposes its full obligations on businesses with more than one billion dollars in global annual revenue. GTO is not such a business. We nonetheless do not sell sensitive data or any other personal data, and we honor the rights in Section 11 for Florida residents. Data breach notification is governed by the Florida Information Protection Act (Section 501.171, Florida Statutes), as described in Section 10. Calls and text messages to Florida residents comply with the Florida Telephone Solicitation Act (Section 501.059, Florida Statutes).
12.4 Nevada residents
Under Chapter 603A of the Nevada Revised Statutes, Nevada residents may direct an operator not to sell their covered information. We do not sell covered information. You may nonetheless submit a verified request to tom@martinmartinhomes.com, and we will record it and honor it if our practices ever change.
12.5 Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island
Residents of these states may have the rights to confirm processing; to access, correct, delete, and obtain a copy of personal data; and to opt out of the sale of personal data, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. We do not sell personal data, engage in targeted advertising, or conduct such profiling. To exercise your rights or to appeal a decision, use the process described in Section 11. Several of these states require covered businesses to honor universal opt-out signals such as Global Privacy Control; see Section 5.3.
12.6 Other state laws
Washington My Health My Data Act and similar consumer health data laws (including in Nevada and Connecticut): we do not collect consumer health data.
Illinois Biometric Information Privacy Act and similar laws (including in Texas and Washington): we do not collect biometric identifiers or biometric information.
Children’s Online Privacy Protection Act and state laws protecting minors: see Section 14.
13
International Users
13.1 Our services are directed to the United States
GTO operates from Florida, its services are directed to residents of the United States, and we do not intentionally offer services to, or monitor the behavior of, individuals outside the United States. If you visit the Site or contact us from another country, your personal information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your country. By using the Site or contacting us, you acknowledge this transfer. We honor the rights in Section 11 for you regardless of your location, and the following additional information applies where the laws described below are found to apply to us.
13.2 European Economic Area, United Kingdom, and Switzerland (GDPR, UK GDPR, Data Protection Act 2018, and Swiss Federal Act on Data Protection)
Controller. Growth Through Others, 132 W International Speedway Blvd, Daytona Beach, FL 32114, USA, tom@martinmartinhomes.com. We have not appointed a representative in the European Union or the United Kingdom under Article 27 GDPR, or a data protection officer, because our processing of the personal data of residents of these regions is occasional and not on a large scale. If that changes, we will update this Policy.
Legal bases. See Section 4.
Your rights. You have the rights of access, rectification, erasure, restriction of processing, data portability, and objection (including the right to object to direct marketing at any time), and the right not to be subject to a decision based solely on automated processing that produces legal effects. You may withdraw consent at any time. You also have the right to lodge a complaint with your supervisory authority: in the United Kingdom, the Information Commissioner’s Office (https://ico.org.uk); in the European Union, the authority in your member state (listed at https://edpb.europa.eu); and in Switzerland, the Federal Data Protection and Information Commissioner.
International transfers. Personal information is stored in the United States. Where transfers from the European Economic Area, the United Kingdom, or Switzerland occur, we rely on our service providers’ certification under the EU-U.S. Data Privacy Framework (including the UK Extension and the Swiss-U.S. Data Privacy Framework) where available; on Standard Contractual Clauses approved by the European Commission, together with the UK International Data Transfer Addendum, where applicable; or on your explicit consent or the necessity of the transfer for the performance of a contract with you. GTO itself is not certified under the Data Privacy Framework.
Cookies. Consistent with the ePrivacy Directive and the UK Privacy and Electronic Communications Regulations, analytics cookies are set only with your consent.
Marketing. We send marketing emails to residents of these regions only with your consent or, for existing clients, in connection with services similar to those you engaged us for, with an opt-out mechanism in every message.
13.3 Canada (PIPEDA, provincial privacy laws, and CASL)
We collect, use, and disclose personal information with your consent or as otherwise permitted by the Personal Information Protection and Electronic Documents Act and applicable provincial laws, including Quebec’s Law 25. Your information may be stored and processed in the United States and may be accessible to United States authorities under United States law. You may withdraw consent and access or correct your information by contacting us. You may lodge a complaint with the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca). We send commercial electronic messages to Canadian residents only with express or implied consent as permitted by Canada’s Anti-Spam Legislation, and every such message includes an unsubscribe mechanism that we honor within 10 business days.
13.4 Australia (Privacy Act 1988 and the Australian Privacy Principles)
GTO is a small business that may be exempt from the Privacy Act 1988. We nonetheless aim to handle personal information consistently with the Australian Privacy Principles. Your information is disclosed to overseas recipients located in the United States (our service providers). You may access or correct your information and may complain to us and, if you are not satisfied with our response, to the Office of the Australian Information Commissioner (https://www.oaic.gov.au). Our marketing emails comply with the Spam Act 2003.
13.5 Brazil (Lei Geral de Proteção de Dados)
If the LGPD applies, GTO is the controller, our legal bases correspond to those described in Section 4, and you have the rights set out in Article 18 of the LGPD, including confirmation of processing, access, correction, anonymization, portability, deletion, information about sharing, and revocation of consent. You may contact the Autoridade Nacional de Proteção de Dados (ANPD). International transfer to the United States is based on your consent or on the necessity of the transfer for the performance of a contract at your request.
13.6 Other countries
If you are located in another country with a data protection law (for example, Japan’s Act on the Protection of Personal Information, South Korea’s Personal Information Protection Act, India’s Digital Personal Data Protection Act 2023, Mexico’s Federal Law on the Protection of Personal Data Held by Private Parties, New Zealand’s Privacy Act 2020, Singapore’s Personal Data Protection Act, or South Africa’s Protection of Personal Information Act), you may contact us to exercise any rights that law provides, and we will respond consistently with Section 11 and with that law to the extent it applies to us.
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Children’s Privacy
The Site and our services are intended for adults in the real estate industry and are not directed to anyone under 18. We do not knowingly collect personal information from children under 13, consistent with the Children’s Online Privacy Protection Act (COPPA), or from anyone under 18. If you believe a child has provided us with personal information, contact us at tom@martinmartinhomes.com and we will delete it. We have no actual knowledge of selling or sharing the personal information of anyone under 16, and we do not use or disclose the personal data of known minors for targeted advertising or profiling.
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Marketing Communications and Opt-Out
Email. If you check the optional box on an event reservation form to receive coaching emails from Tom Martin, we will send you emails about our coaching, workshops, events, and content until you unsubscribe. If you reserve a seat without checking that box, we will email you only about the event you reserved. If you book a consultation, become a client, or subscribe in another way, we may also send you emails about our coaching, workshops, events, and content, and you may opt out at any time. Every marketing email includes an unsubscribe link, and we honor opt-outs within 10 business days (usually immediately), as required by the CAN-SPAM Act. Unsubscribing from marketing does not stop transactional emails, such as event or booking confirmations or replies to your questions. Our emails include our postal address and identify GTO as the sender.
Text messages and calls. We contact you by phone or text message only as described in our Terms and Conditions: about your booking or inquiry, or, for marketing text messages sent using automated technology, only with your separate prior express written consent, as required by the Telephone Consumer Protection Act and the Florida Telephone Solicitation Act. Reply STOP to any text message to opt out and HELP for help. Message and data rates may apply. Mobile phone numbers and text message opt-in consent are never shared with third parties for their own marketing purposes.
Do not call. Ask to be added to our internal do-not-call list at tom@martinmartinhomes.com.
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Business Transfers
If GTO is sold, merged, or reorganized, or transfers all or part of its assets, or in the event of the owner’s incapacity or death, personal information may be transferred to the successor as part of that transaction. The successor will be bound by this Policy with respect to the information transferred, unless you are notified otherwise and given a choice.
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Changes to This Policy
We may update this Policy from time to time. When we do, we will post the revised Policy on the Site with a new “Last Updated” date. If a change materially reduces your rights or changes how we use personal information we have already collected, we will notify you by email (if we have your address) or by a prominent notice on the Site before the change takes effect and, where required by law, obtain your consent. Your continued use of the Site after a change takes effect means you accept the revised Policy. Prior versions of this Policy are available on request.
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Contact Us
Growth Through Others
Attn: Tom Martin, Privacy
132 W International Speedway Blvd
Daytona Beach, FL 32114
United States
Email: tom@martinmartinhomes.com
Phone: (407) 921-3645