Privacy Policy

1. Information We Process

We may obtain information about you in a variety of ways, including through your use of our Services, when you call, email or otherwise communicate with us (including through social media), or when you participate in events or other promotions.

The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the “GDPR“). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.

These are the categories of personal information we collect, which may vary based on the Service being used:

1. Identifiers (e.g., a real name, alias, unique personal identifier, online identifier, IP address, email address, account or other similar identifiers).
2. Personal Records (e.g., name and surname, email address and username. Some personal information included in this category may overlap with other categories).
3. Usage data and network activity (e.g., information on a consumer’s interaction with a website, application, or advertisement. See Information collected by Automated Means below for further details).
4. Geolocation data (e.g., physical location or movements).
5. Sensory data (e.g., audio, electronic, visual, or similar information).
6. Commercial information (e.g., records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies).

Please note that when using certain Services, you may choose to input or provide access to certain physical or health-related information about yourself. Such information will be stored locally on your device and accessed only as described in the “Information collected from you” subsection below.

2. Sources of Information and Purposes of Use

Some of this information you provide to us and some we collect when you use our Services. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others, and from previous owners and data controllers. You may choose not to provide some or all of your personal information to us but doing so may prevent us from providing our Services to you or limit our ability to provide you with the level of service that you would otherwise expect from us.

Information collected from you

The following are examples of the types of information we may collect directly from you:

• Feedback: From time to time, we may request your opinions, suggestions, or modification and improvement ideas (“Feedback“) through surveys, or other similar requests. Any responses you provide are voluntary and shall be owned by Growly and may be used by Growly in our sole discretion.
• Name: We require your name to personalize your user experience.
• Telephone number: We may require your phone number for the technical provision of our Services to you.
• Email address: We use your email address to communicate with you about the products and Services we offer, responding to requests, inquiries, comments, and suggestions and updating you with information about your account.
• Username and/or PIN: Certain of our Services use this information to facilitate your access to our website or mobile application and validate your login for your security.
• Other User Information: When using certain Services, you may choose to input or provide access to certain information about yourself, such as photographs, physical and health related information, or other information to enhance your experience of the Services we provide. This information will be stored on your device and will not be transmitted to Growly unless we notify you otherwise at the time of entering the information or granting access to the information.
• Payment Information: In the event you purchase products or Services directly from us, we, or a third party on our behalf, may collect payment card and other payment information, solely as required to process payment for such purchase. Your failure to provide such information may prevent you from using our services.
• Location Information: When you use our Apps, we and our third party partners may detect your general location (e.g., city and state). Additionally, we may also collect precise location data (e.g., longitude/latitude) but only when you consent within the app to sharing your precise location.
• Apple Services: Certain of our Services facilitate optional syncing with Apple Services such as Apple Face Tracking and the Apple “Health” App to enhance your experience of the Services we provide. In such cases, we will ask you for permission to do this and will explain the benefit of syncing the information. This information will be stored on your device and will not be transmitted to Growly, and we will not transmit this data to external servers or any other third parties.

Information collected by automated means (“Automated Information”)

We may collect Automated Information through the use of cookies, and other technologies. In addition to cookies, such other technologies may include:

• “Pixel tags” (also known as a “clear GIFs” or “web beacons”)
• “HTML5”

Automated Information includes information such as:

• IP address
• Operating system used (for example: iOS)
• Internal resolution of the browser window
• Device type
• Country code
• Identifiers associated with technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address)
• Dates and times of access
• IDFA
• Subscription information
• Latitude/longitude (if you allow location tracking)
• AdvertisingID (such as Google’s AdvertisingID and Apple’s IDFA)
• Adjust ID

Information uploaded by users of the Scan Hero app

Users of the Scan Hero app can avail of an image sharing feature and choose to upload scanned images for sharing with their friends. When a user uploads an image, then it will be processed and stored by us for up to 48 hours. After this time, the image will be permanently deleted.

3. How We May Use Your Personal Information

In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:

• Service delivery and Customer support: Maintaining or servicing accounts, providing customer service, operation our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments.
• Service improvement: Conducting statistical analyses or other research activities to optimize our features and provide you with new ones.
• Profiling: Measuring our advertising and marketing activity.
• Troubleshooting: Ensuring the quality and the proper functioning of our Services by analyzing, preventing, and correcting failures and bugs.
• Targeted advertising and marketing: Understanding our customer in order to more effectively market our Services.
• Quality and Safety Maintenance and Verification: activities related to improving the quality of the Services we provide.
• Compliance with legal obligations
• Defense: Establishing, exercising, or defending our rights and those of our employees.

4. How We May Share Information about You with Others

Your personal data may be transmitted to trusted and reliable third parties. This happens only when there are lawful grounds for the transmission. We don’t sell your data, including your images, to third parties under any circumstances.

The types of third parties to which your data may be transmitted are as follows:

• Third parties that carry out activities related to our business and operations (e.g., IT or storage service providers).
• Third parties that collect personal data about you to show personalized advertising (e.g. Facebook, Pinterest, Snapchat, Google Ads).
• Advisors and new owners, in the event that we carry out a corporate transaction.
• Public, judicial, or police authorities, within the limits established by applicable laws.
• Other parties as necessary (for example, competent authorities) if we have reason to believe that your actions are inconsistent with our user agreements or policies.

5. Social Media and Other Communications

We maintain a presence on several social networking and blogging platforms, such as Facebook, Instagram, Google, LinkedIn, Twitter, Snap, TikTok and Pinterest. We may incorporate some third-party social networking features into our Services. Through these platforms and features, we receive or may share information about you, and this Privacy Policy applies to that information as well.

6. Your Choices and Rights

You have the following rights in relation to how we use your personal information:

• Access: you may request access to your personal information and receive copies of it;
• Correction: you may have inaccurate/incomplete personal information corrected and updated;
• Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
• Deletion: in certain circumstances, you can request a right “to be forgotten”.
• Portability: in certain circumstances, exercise the right to data portability.
• Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time.

7. Legal basis for processing data

In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services. It may also be necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims. We may also process personal information as specifically permitted by applicable legal requirements.

8. Data Retention

We retain personal data used for defense purposes for a maximum of ten (10) years from your most recent interaction with the app, or from the expiration of your subscription. We retain personal data used for the purpose of compliance with legal obligations for a maximum of five (5) years. We retain the personal data for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. The images uploaded by the users of the Scan Hero app will be processed and stored by us for up to 48 hours.

9. International data transfers

We may transfer your personal information to countries other than the country in which the data was originally collected. Specifically, we may transfer personal information from the European Economic Area to countries that the European Commissions has deemed to adequately safeguard personal information, or pursuant to standard contractual clauses.

10. Information for Residents of California: Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy.

• Access Rights: request to know what personal information we have collected about you.
• Data Correction Rights: request to have inaccurate personal information corrected.
• Data Deletion Rights: request that we delete your personal information.

To make a request for access, correction, or deletion according to your rights under CCPA, send your request to truong@growly.life.

11. Information for Residents of Mainland China

If you are a resident of Mainland China, the PRC laws and regulations contain rules that are in addition to those set forth elsewhere in this Privacy Policy. We only collect your information to the extent necessary to provide one or more of the Services. Sensitive personal information access is disabled by default. Your personal information collected from Mainland China will be stored in a location within Mainland China.

12. Online Privacy Choices and Rights

• Device permissions: You can change your settings on your device to either consent or oppose the collection of corresponding information (e.g. camera, microphone).
• Uninstall: You can stop all information collection by the app by uninstalling the app.
• Email: You may unsubscribe at any time by following the instructions contained within the email or sending a request to truong@growly.life.
• Location information: You may be able to opt out from further allowing us to have access to such location data by managing your location preferences.
• Advertising Opt-Outs: You may choose whether to receive some Interest-based Advertising by submitting opt-outs (DAA, NAI).

13. How We Protect Personal Information

We use various efforts intended to safeguard the security and integrity of personal information collected through our Services. However, we cannot guarantee absolutely safety.

14. Links to Websites and Third-Party Content

We may provide links to websites and other third-party content that is not owned or operated by us. We are not responsible for the privacy practices of any entity that we do not own or control.

15. Information Relating to Children

We do not knowingly collect information from children under the age of 13 (or 16 in the EEA). If you are not over 13 years of age, DO NOT DOWNLOAD OR USE THE SERVICES. If you believe we have personal information from a child under 13, please contact us at truong@growly.life.

16. Updates to Our Privacy Policy

We reserve the right to update this Privacy Policy. When we post changes, we will update the date of this Privacy Policy.