GrowersGo Privacy Policy

‍‍Last update: March 21th, 2023

GrowersGo LLC (GrowersGo and affiliates, collectively referred to as “GrowersGo,” “us,” “we,” or “our”) is committed to protecting and respecting your privacy in connection with your use of our websites, including www.growersgo.com (the “Websites”) and the products, services and features that may be referenced on the Websites or otherwise offered by GrowersGo (our “Products and Services”). These include but are not limited to our mobile applications and administrative tools related to our GrowersGo guiding thread to grow offerings, including the websites and mobile apps offered by GrowersGo, and the products and services offered through those respective sites and apps (“GrowersGo App”), collectively for purposes of this Privacy Policy referred to as the “GrowersGo platform” or “Platform,” which may be updated from time to time at the sole discretion of GrowersGo.

‍This privacy policy (“Privacy Policy”) and any other documents referred to herein cover personal information collected through the GrowersGo Platform and in connection our Products and Services. We encourage you to please review the GrowersGo Cookie Policy for more information about our use of cookies and other tracking technologies. We also encourage you to review our other terms and notices, included in the GrowersGo Terms and Conditions regarding your use of the GrowersGo Website and Apps

Please read the following carefully to understand our practices regarding your personal information and how we will collect, use and disclose your personal information. 

‍Collection of personal information

For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through the GrowersGo platform will be apparent by the context of the page and/or the circumstances in which the personal information is being collected. This may include collection and processing of personal information including, but not limited to, the following categories of information.

‍Information you provide to us

GrowersGo may collect the following categories of personal information about you that you choose to provide to us when you use the GrowersGo Platform or otherwise interact with or receive our Products and Services:

• Contact information and identifiers.  When you use our Platform, we may ask you to provide certain contact information including your first and last name and email address. We may also collect your social media identification number if you choose to access the Platform via a social media platform. 
• Account Information. If you decide to set up an account with us, we may ask you to provide certain additional contact information including, for example, your first and last name, e-mail address (personal and/or work), gender, country, personal and professional situation, as well as password and other authentication-related information. 
• We may present you with surveys or other information forms on our Platform order to provide you with information about our Products and Services that we think may be of interest to you or for research purposes. These surveys may give you the opportunity to describe certain things about you, such as your current personal and professional situation.
• Profile and demographic information.  Through your account on our Platform, you may have to opportunity to provide additional information about yourself, such as your age, gender and country. 
• Communication information.  When you send or respond to emails, messages, or other communications from GrowersGo, we may collect your email address, name, and any other personal information you choose to include in the body content of your communications. In addition, when you interact with certain  features of our Platform, we may collect the content of those communications.

Information we automatically collect

Our Platform, including the Websites, may collect information from you automatically as your use our platform, including individual Websites and Apps. This information may include: 

• Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Websites and Apps you are visiting; and
• Usage data, such as geolocation data, browsing history, time spent on the Platform, pages visited, links clicked, language preferences, performance of features, patterns of use, and the pages that led or referred you to our Platform including individual Websites and Apps.  
• Cookies and web-beacons  We may use cookies and other tracking technologies such as pixels, web beacons, embedded scripts, and tags (“Cookies”). We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. 

Aggregated, anonymous, and de-identified data

We may create aggregated, anonymous, or de-identified data from personal information by removing data components that make the data personally identifiable to you, or potentially personally identifiable to you, or through obfuscation or other means. Once information is aggregated, anonymized, or de-identified such information is no longer personal information, and use of the data is not subject to this Privacy Policy.

‍Use of personal information

‍We may use your personal information in the following ways:

• To provide our Products and Services, including the delivery of content and facilitation of interactive features;
• To communicate with you regarding the GrowersGo, products and services;
• To notify you about updates or changes to the GrowersGo platform, products and services;
• To provide customer service, answer your questions or requests for information, or handle your complaints;
• To facilitate payment transactions, manage your orders, and account for applicable sales taxes;
• To inform businesses, government entities, hospitals, universities and other organizations and groups that wish to make our products and services available to their members, employees and their families, patients, customers, residents or others (collectively, our “Partners”) about your registration and, in limited cases, use of the products and services;
• To effectuate our performance on any agreements that we may have with you;
• To maintain and improve the quality of the GrowersGo platform, products and services, including to perform research and development, understanding our user trends, and understand the effectiveness of our marketing and advertising;
• To provide you with information about new products and services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;
• To serve our advertisements to you through third-party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law;
• To protect ourselves, you and others; preventing fraud and other unlawful or unauthorized activity; and creating and maintaining a trusted, secure, and reliable online environment; and
• To comply with our legal obligations; respond to subpoenas, court orders or legal process; and to establish or exercise our legal rights or defense against legal claims.

Sharing of personal information

‍We may also disclose your personal information with the following categories of third parties:

• Our service providers. In some circumstances, based on your specific requests, we may need to disclose your personal information to a third party so that they can provide a service on our behalf, such as to help deliver products or services that you have requested. These service providers may include services such as analytics, payment processing, advertising and marketing, website hosting, customer and technical support, and other services. 

Our service providers have access to your personal information only to perform these tasks on our behalf and are obligated to maintain the confidentiality and security of your personal information, and to not disclose or use the information for any other purpose, consistent with this Privacy Policy and applicable law.

• Third party advertising platforms. We may share your personal information with third party platform providers who assist us in serving advertising regarding the GrowersGo, products and services to others who may be interested.  We also partner with third parties who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.
• Our Partners. In limited cases, we may provide certain personal information to our Partners, which may include your employer, in order to provide the GrowersGo platform, products and services as a benefit of your employment.
• Third party business partners. In limited cases, we may provide certain personal information to third party businesses with which we have a joint promotional relationship or other trusted partnership. This type of sharing will most often be consistent with your notice, consent, direction, and/or reasonable expectations in light of the circumstances in which you provided the personal information.
• Compliance and harm prevention. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, such as to comply with a subpoena, bankruptcy proceeding, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of GrowersGo, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We may also disclose personal information where we believe that doing so would be in accordance with or required by any applicable law, regulation or legal process
• Affiliate and business transfer. If GrowersGo, including any of its subsidiaries, brands or affiliates, is involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity. If such transfer results in a material change to the use of your personal information, we will provide notice before your personal information is transferred and/or becomes subject to a different privacy policy.

‍Your Rights and Choices 

‍You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices using the information in the Contact us section at the end of this Privacy Policy.

Privacy rights, choices, and preferences. If you have an account on our platform, please visit your account for any privacy rights, choices, or preference options that may be offered. In your GrowersGo user profile, you are able to make additions or edits to any of your personal, payment, or membership information, and you may request to delete your account. You may also submit a request to master@growersgo.com. 

Opting out of receiving electronic communications from us. You will not receive promotional electronic communications from us if you have opted out of receiving such communications. If you wish to opt out, you may opt out via the unsubscribe link included in such emails or by contacting us at master@growersgo.com. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our products and services or for other reasons disclosed in this Privacy Policy. For EU-based users only, we will ask for your consent prior to sending you any promotional electronic communications. 

Data security: The security of your personal information is important to us. We follow generally accepted standards, practices, and procedures to protect the personal information submitted to us, both during transmission and once it is received. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.  

‍If you have an account with us and you suspect unauthorized use of your account or its credentials, you should notify us immediately using the information in the Contact Us section at the end of this Privacy Policy.

‍Cookies and tracking technologies: When you visit the GrowersGo platform, we may collect information from you automatically through Cookies. We also rely on service providers and other partners to provide many features of our Platform using data about your use of the Platform, which may include personal information. Please review the Cookie Policy for more information regarding our collection of Cookies, the purposes for which we use them, and how to exercise your preferences regarding them including the ability to opt-out through our Platform or via your browser.

The GrowersGo platform may use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the platform and the volumes of usage of the products and services. This is done to ensure that the Platform and its associated Products and Services are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.

‍We will acquire consent from you in order to use such trackers or provide you with the opportunity to opt-out of such trackers, to the extent required by applicable law. For more information on the types of cookies used by GrowersGo and your ability to restrict the behavior of cookies or disable them in your browser’s settings, please refer to the Cookie Policy.

‍We do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

‍Other tracking on our Platform.  Our Platform, including our Websites, may utilize tracking technologies to collect and record your activities and movements across our Websites throughout your browsing session, including to track button clicks, mouse movements, scrolling, resizing, touches, keystrokes, data entered, device information and orientation, browser visual elements, and screen size (“Session Data”), for purposes of our own internal analytics and improving our products, services, and user experience. Such tracking may include recorded sessions, which we may play back for these purposes.

‍Our platform also utilizes live chat and/or chat bot technology, which visitors to communicate directly with our automated customer service system and/or customer service representatives via a chat window about our products and services. Text entered into this form prior to submission may be collected, retained, and used by GrowersGo for our business purposes, including by our customer service and other personnel and service providers.

‍We may share Session Data and chat bot correspondence data with our third-party analytics or service providers, which may change from time-to-time, for these purposes, who will use the data solely on the behalf of, and for the benefit of, GrowersGo. 

‍ If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us at master@growersgo.com. If we become aware that we have collected personal information from children under age 13 without parental consent, we will take steps to remove that information from our servers.

‍The subsidiaries, service providers or other third parties described in this Privacy Policy and to whom GrowersGo may disclose your personal information may be domiciled abroad, and, in particular, outside the European Union and the United Kingdom. In such case, GrowersGo will require them to take, in accordance with applicable legislation, contractual, organizational and technical measures designed to ensure an adequate level of protection of your personal information, such as the use of Standard Contractual Clauses approved by the European Commission.

We remain certified under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (https://www.privacyshield.gov/) and are committed to the important privacy principles set forth in Privacy Shield. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.

‍However, in light of the Schrems II decision by the European Court of Justice on July 16, 2020, we are no longer relying exclusively on EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield and have implemented other transfer mechanisms such as Standard Contractual Clauses to address any transfers of personal information to the U.S., consistent with applicable law.

‍For personal information collected from individuals located in the European Union, Switzerland and the United Kingdom, you have the ability to opt out of whether such personal information is disclosed to a third-party (apart from service providers) or is to be used for a purpose that is materially different for the purpose for which it was originally collected or subsequently authorized. You can contact GrowersGo at master@growersgo.com in order to make such choices.

‍Links to other websites: Our Platform, including its Websites and Apps, may contain links to other websites that are not operated by GrowersGo. We are not responsible for the content or privacy policy policies of websites we do not own or control, and our Privacy Policy does not apply to third-party websites. We strongly suggest you review the privacy policies for third-party websites to understand how your personal information is used and stored by those websites.

‍European and UK Privacy Notice

 This European and UK Privacy Notice applies to any individuals located within the European Economic Area (EEA) or the United Kingdom (UK) from whom we may have collected personal data from any source, whether online or offline, including through your use of our Websites. We provide this European Privacy Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states.  Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy. 

European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, to access, to rectification, to erasure, to restrict processing, to data portability, and to object with respect to collected personal data.  For the purposes of this European and UK Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.

Basis for processing your personal data

GrowersGo relies on one or more legal bases to process your personal data under applicable law.  We may process personal data (i) as necessary to perform our contractual obligations to you; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.

Legitimate business interests.  We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below.  To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others, and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.

Our legitimate interests generally include: 

• Provide you with requested GrowersGo products and services.
• Provide you with customer service and support, including to send you messages and provide user support, and to facilitate other communications that you request or are required to render our products and services to you. This may include providing you with information about new products and other opportunities we offer that we believe may be of interest to you based upon your interactions with us, and to personalize, measure, and improve such offers.
• Maintain and improve the quality of the GrowersGo platform and the products and services that we offer through our platform, including to customize our sites and products to better fit your needs as a user, develop new sites and products, to perform internal analytics for new and existing products (such as our user accounts and related features) and to conduct research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
• Protect you and others and to create and maintain a trusted environment, such as to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable sites and products, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. 
• Provide, personalize, measure and improve our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing.  This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.
• For risk management purposes, including compliance with our legal and regulatory obligations and for fraud detection, prevention and investigation, including “know your customer,” anti-money laundering, conflict and other necessary onboarding and ongoing client checks, due diligence and verification requirements, credit checks, credit risk analysis, compliance with sanctions procedures or rules, and tax reporting.
• Comply with laws and regulations applicable to us, including any legal or regulatory guidance, codes, or opinions and to other legal process and law enforcement requirements, including any internal policy based on or reflecting legal or regulatory guidance, codes, or opinions. We may also respond to subpoenas, court orders, or legal process, and establish and exercise our legal rights or defenses against legal claims. 

Your privacy rights 

In certain circumstances, individuals located within the EEA and UK may have the following data protection rights regarding their personal data:

• Right to access. You may have the right to request confirmation of whether GrowersGo processes personal data relating to you, and if so, to request a copy of that personal data.
• Right to rectification. You may have the right to request that GrowersGo correct or update your personal data that is inaccurate, incomplete or outdated.
• Right to deletion. You may have the right to request that GrowersGo erase your personal data in certain circumstances provided by law.
• Right to restrict processing. You may have the right to request that GrowersGo restrict the use of your personal data in certain circumstances.
• Right to object to processing. You may have the right to object to GrowersGo processing of your personal data, under certain conditions.
• Right to data portability. You may have the right to request that GrowersGo export the data that we have collected to you or another company, under certain conditions.

Where the processing of your personal data is based on your previously provided consent, you have the right to withdraw your consent at any time.  If you would like to exercise any of these rights, please submit a written request master@growersgo.com. We will respond to these requests in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

You may also have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority.  

Retention of personal data

We will retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include:  (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

‍Changes to this Privacy Policy

‍We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the GrowersGo platform, including the Websites. We may take reasonable measures to notify you via email and/or a prominent notice on our platform before certain changes become effective. We will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

‍Contact Us

‍Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to master@growersgo.com. 

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