Privacy policy
Privacy, in plain words
Draft dated 7 November 2026. Applies to Growth Dept ACR at acr.growthdept.ai.
1. Two kinds of people
People who use ACR: store staff and Growth Dept staff who sign in. We hold their accounts and decide how that data is used.
Shoppers: people a store contacts through ACR, usually because they started a checkout. The store decides who is contacted and why. We process shoppers’ data for the store, under our agreement with it, and only to run its campaigns and report their results.
2. What we collect from merchants and people who use ACR
- For each store: its name and website, the company details you enter for carrier registration (legal name, entity type, registration number, business address, a representative’s name, email and phone), your support email and policy links, and your campaign settings.
- For a connected Shopify store: the shop’s domain and the access token Shopify issues to the Growth Dept ACR app, stored encrypted. Mailbox grants and mail-server passwords are stored encrypted too.
- Your name and email address, your role in each organization, and when you last signed in.
- If you sign in with Google: the name, email address and Google account id Google shares with your permission.
- If you use a password: a hash of it, never the password itself. Two-factor secrets are stored encrypted.
- A hash of each session token, when it started and expires, and your browser’s user-agent string.
- An audit log of changes to accounts, stores, campaigns, access and API keys, and of support visits by Growth Dept staff.
3. What we process about shoppers
- Contact details the store sends: name, email address, phone number, country, region, time zone and language.
- Checkout and order details: items, totals, currency, discount codes, the link back to the cart, and order ids.
- Consent records for calls, texts and email, with where and when consent was given, and the store’s suppression list.
- Conversations: call transcripts and summaries, call recordings when the store records calls, and the texts and emails sent and received.
- Link clicks and email opens, and the answers to the store’s conversation questions.
4. Text messages and calls: consent and sharing
Stores use ACR to call and text shoppers who have agreed to be contacted. Where a store’s campaign has the consent check on, which is the default, a shopper is called or texted only when the store has a record of consent for that channel.
We do not sell, rent or share mobile phone numbers or text-message consent with third parties or affiliates for their marketing or promotional purposes. Text-message opt-in data and consent are never shared with anyone except the providers that deliver the messages for the store, and only to deliver them.
A shopper can reply STOP to any text to stop texts from that store, or HELP for help. A shopper who asks on a call not to be called again is not called again by that store. Message and data rates may apply. See the SMS terms.
Calls are made by an AI agent that says it is an AI when asked. When a store records calls, the agent says so where the law requires it.
5. Requests that come through Shopify
Stores that install the Growth Dept ACR app receive Shopify’s privacy requests through it, and ACR acts on them automatically:
- A customer asks for their data (Shopify’s customer data request): ACR gathers everything the store holds about that customer (their lead record, checkouts, orders, runs, conversations and hand-offs), encrypts it, and asks the store’s admins to download it and pass it on. The export is kept for 30 days.
- A customer asks to be erased (customer redact): ACR removes the customer’s name, email address, phone number and other contact details, the content of their calls, texts and emails, call recordings and transcripts, and the raw event data, and cancels any outreach still scheduled. A record that the customer was redacted remains, so they are not contacted again from old data.
- A store uninstalls the app: outreach stops at once and the connection is closed. When Shopify then sends its shop redact request, 48 hours after the uninstall, ACR deletes all of that store’s shopper data and the installation record. The merchant’s ACR account, campaigns and settings stay until the merchant asks us to delete them.
Only counts of what was gathered or removed are written to our logs, never the data itself.
6. Why we use it
- Account data: to sign you in, show you the stores you can access, keep the service secure and answer support requests.
- Shopper data: to decide whether and when to contact a shopper, hold the conversation, stop when they buy or opt out, and report the store’s results, for that store and nothing else.
We do not sell personal data, use shoppers’ data for our own marketing, or share one store’s shoppers with another store.
7. Who else handles it
These providers process personal data for us, each only for the job listed.
| Category | Provider | What it handles |
|---|---|---|
| Hosting and database | Vercel and Neon, in the United States | The application and everything it stores |
| Telephony and texts | Twilio | Phone numbers, calls and text messages |
| AI and voice | ElevenLabs, and an AI text provider when a store has one switched on | The voice agent, and written replies |
| Email and sign-in | Google, or Microsoft when a store connects a Microsoft mailbox | A store's own mailbox, and sign-in with Google |
| Store data | Shopify | Checkouts and orders, for stores that install the app |
| Payments | Stripe, once billing is switched on for standalone stores | Subscription billing; card details stay with Stripe |
8. Google user data
Growth Dept ACR’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Google sign-in data is used only to sign you in. A connected Gmail mailbox is used only to send the store’s campaign emails and read replies to them. We do not use Google user data for advertising or to train AI models.
9. Cookies on acr.growthdept.ai
The application sets cookies that keep you signed in and hold a sign-in in progress. This site sets no analytics or advertising cookies.
10. How long we keep it
- Shopper records, conversations, call recordings and transcripts: for as long as the store uses ACR, unless the store deletes them or the shopper is erased through a privacy request. [RETENTION PERIODS TBD: a fixed limit for shopper records, conversations and recordings.]
- Customer data exports for Shopify data requests: 30 days.
- All shopper data for a store that uninstalled the Shopify app: deleted when Shopify’s shop redact request arrives, 48 hours after the uninstall.
- The suppression list: kept while the store uses ACR, so an opt-out keeps working.
- Account data: until you or your organization ask us to delete it. [AUDIT LOG RETENTION TBD]
11. How it is protected
Each store’s data is separated by row-level security in the database. Secrets are encrypted with AES-256-GCM, and passwords, session tokens and API keys are stored only as hashes. The security page has more.
12. Your choices
Email hello@growthdept.ai to see, correct or delete your account data. Shoppers who want their data removed, or who want to know why they were contacted, should ask the store they dealt with; a Shopify store’s erasure and data requests reach ACR automatically, as section 5 describes. We act on the store’s instruction, and we pass a request we receive directly to the store.
13. Changes
We may update this policy. The current version is always at acr.growthdept.ai/privacy with its date.