PRIVACY POLICY

European Union - General Data Protection Regulation (GDPR)
GRO Solutions LLC

Effective Date: March 21, 2026
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1. Introduction

GRO Solutions LLC (“we,” “our,” or “us”) is committed to protecting the personal data of

individuals located in the European Union and European Economic Area. This Privacy Policy

explains how we collect, use, store, and protect your personal data when you visit our

website and use our services, in accordance with Regulation (EU) 2016/679 (the General

Data Protection Regulation, or “GDPR”).

2. Data Controller

The data controller responsible for your personal data is:

Entity - GRO Solutions LLC

Registration - QFC No. 04838

Address - Qatar Financial Centre, Doha, Qatar

Email - info@cupofcoffee.studio

3. Personal Data We Collect

We collect the following categories of personal data when you interact with our website:

Data Category Details

Full Name - Your first and last name, as provided by you

Email Address - Your email address, as provided by you

We do not collect any special categories of personal data (e.g., health data, biometric data,

racial or ethnic origin).

4. Legal Basis for Processing

Under Article 6 of the GDPR, we process your personal data on the following legal bases:

• Consent (Article 6(1)(a)) - You have given clear, affirmative consent for us to process

your personal data for the specified purposes.

• Legitimate Interest (Article 6(1)(f)) - Processing is necessary for our legitimate

interests, such as improving our services and communicating with you, provided

these interests are not overridden by your fundamental rights and freedoms.•

Contractual Necessity (Article 6(1)(b)) - Where processing is necessary to perform a

contract with you or take pre-contractual steps at your request.

5. Purposes of Processing

We use your personal data for the following purposes:

• To create and manage your account on our platform

• To communicate with you regarding our services, updates, and announcements

• To respond to your inquiries and provide customer support

• To comply with our legal and regulatory obligations

• To improve and personalise your experience on our website

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in

this policy, or as required by applicable law. Specifically:

• Account data (name and email) is retained for the duration of your active account and

for up to 24 months following account closure or your last interaction with us.

• Upon expiry of the retention period, your data will be securely deleted or

anonymised.

You may request deletion of your data at any time by contacting us at info@cupofcoffee.studio.

7. Your Rights Under the GDPR

As an EU/EEA data subject, you have the following rights under the GDPR:

• Right of Access (Article 15) - You may request a copy of the personal data we hold

about you.

• Right to Rectification (Article 16) - You may request correction of inaccurate or

incomplete personal data.

• Right to Erasure (Article 17) - You may request deletion of your personal data (“right

to be forgotten”).

• Right to Restriction of Processing (Article 18) - You may request that we restrict

processing in certain circumstances.

• Right to Data Portability (Article 20) - You may request your data in a structured,

commonly used, machine-readable format.

• Right to Object (Article 21) - You may object to processing based on legitimate

interests or for direct marketing purposes.

• Right to Withdraw Consent - Where processing is based on consent, you may

withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@cupofcoffee.studio. We will

respond within 30 days of receiving your request.8. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European

Economic Area, including Qatar. Where such transfers occur, we ensure appropriate

safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission

• An adequacy decision by the European Commission, where applicable

• Your explicit consent for the transfer, where no other safeguard is available

9. Data Security

We implement appropriate technical and organisational measures to protect your personal

data against unauthorised access, loss, destruction, or alteration. These measures include,

but are not limited to:

• Encryption of data in transit (TLS/SSL) and at rest

• Access controls limiting data access to authorised personnel only

• Regular security assessments and audits

10. Third-Party Sharing

We do not sell your personal data. We may share your data with trusted third parties only in

the following circumstances:

• Service providers who assist us in operating our platform (e.g., hosting, email

delivery), under data processing agreements compliant with Article 28 of the GDPR

• Legal authorities, where required by law or to protect our rights

11. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies. Where these technologies

process personal data, we obtain your consent through a cookie banner in compliance with

the ePrivacy Directive. For details, please refer to our Cookie Policy [link to be inserted].

12. Children’s Data

Our services are not directed at individuals under the age of 16. We do not knowingly collect

personal data from children. If you believe a child has provided us with personal data, please

contact us and we will take steps to delete it promptly.

13. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the GDPR, you have the

right to lodge a complaint with a supervisory authority in the EU Member State of your

habitual residence, place of work, or place of the alleged infringement.14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any material changes will be

communicated via our website or by email. The “Effective Date” at the top of this policy

indicates the most recent revision.

15. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please

contact us:

Entity - GRO Solutions LLC

Email - info@cupofcoffee.studio

Address - Qatar Financial Centre, Doha, Qatar