Privacy Data Policy
This Privacy Notice does not apply to the practices of third parties that GROWTHSTER does not own or control, or to individuals that GROWTHSTER does not employ or manage.
As a service provider, this Privacy Notice does not apply to the data that we receive or handle on behalf of our subscribers, such as information that we receive through our marketing automation software services or other GROWTHSTER services. Such information specifically includes, without limitation, Google user information that we receive through plugins as well as extensions of Google products and services, and is governed by the terms of the applicable subscription services agreement, rather than this Privacy Notice.
GROWTHSTER endeavors to process Personal Data in compliance with the European Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation or “GDPR”).
You can request a copy of this Privacy Notice by contacting us at firstname.lastname@example.org.
I. PRIVACY STATEMENT SCOPE
Generally, we intend to collect only the Personal Data that is provided voluntarily by Visitors so that we can offer information and/or services to those individuals or offer information about the services that GROWTHSTER offers.
II. TYPES OF INFORMATION WE COLLECT
2.1 GROWTHSTER collects personal data that is provided voluntarily by Visitors so that we can offer information and/or services to those individuals. Such information may include, without limitation: contact information that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages; commercial information that helps us do business with you, such as the types of products and services that may interest you, information on your company’s size, geographic locations and demographics; transaction information about how you interact with GROWTHSTER including purchases, inquiries, Client account information; browser and device information (including IP Address), and information collected through cookies and other similar technologies.
III. SOURCES OF DATA WE COLLECT
The collection of this information allows us to customize a Visitor’s or Client’s online experience; improve the performance, usability, and effectiveness of the Services; advertise and market our services; measure the effectiveness of our marketing activities, and generate and analyze statistics about our Clients use our Services.
Your Personal Data is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by applicable law. For example, if you send us an email message requesting information about GROWTHSTER, we will use your email address and other information you supply to respond to your request. Where we ask to use your Data for additional purposes, we will ask your permission for this at the point of collection.
As stated on our privacy statement scope, we generally collect only the Personal Data necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection and where applicable, unless this Personal Data is required for the performance of a contract or the follow-up of pre-contractual requests, explicit consent will be requested.
3.2 Offline: We collect information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact a GROWTHSTER representative.
3.3 Through You: GROWTHSTER collects information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Data, this information does not personally identify you or any other user of the Sites.
3.4 Through Your Browser or Device: When Visitors or Clients visit any of our Websites, we may collect (automatically log) their IP address (the unique address identifying a computer on the Internet) and standard web log information, such as browser type and the pages accessed on our Websites. The IP address will be automatically recognized by our servers. We may also use this information in aggregate form to maintain and improve our Websites and the Services and to generate and analyze statistics about our Websites and the Services and our Clients’ use of the Services (under legitimate interest, i.e. the freedom to do business)
Certain information is collected by most browsers or automatically through your devices, such as your IP address (the unique address identifying a computer on the Internet) and standard web log information, such as browser type and the pages accessed on our Websites. Your IP address will be automatically recognized by our servers. Collecting IP Addresses is standard practice and is done automatically by many websites, applications, and other services. GROWTHSTER uses IP Addresses to maintain and improve our Websites and the Service, help diagnose problems with its servers, and to generate and analyze statistics about our Websites and the Services and our Clients’ use of the Services (under legitimate interest, i.e. the freedom to do business)
3.6 Through Cookies and Other Similar Technologies: "Cookies" include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Sites. When our Websites are accessed, “cookies” may be placed by or for us on the visiting computer. When a Client accesses a Service by logging in using a password and/or user ID, we send a "session cookie" to that computer. This type of cookie helps us recognize visits to multiple pages on the Websites during the same session, so that we don't need to ask for a password on each page. Once a registered Client has logged out or a browser is closed, this cookie expires and no longer has any effect. We may also use longer-lasting cookies for other purposes such as to display an email address on a sign-in form, to avoid the need to retype the email address on each log in to a Client account. We encode our cookies so that we can interpret the information stored in them. You are free to decline our cookies if the browser permits, but doing so may interfere with use of our Websites.
3.7 By Aggregating Information: We may also share aggregated or anonymized information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information such as the types of Offerings our customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which we collected through our technology. If we are required under applicable law to treat such information as personal information, then we will only disclose it as described above. Otherwise we may disclose such information for any reason.
IV. HOW WE USE THE INFORMATION WE COLLECT
Our legal basis for collecting and using the Personal Data described below will depend on the Personal Data concerned and the specific context in which we collect it. Our legal basis for processing Personal Data in certain circumstances will also be based on your consent to do so or where we need the Personal Data to perform a contract with you or to enter into a contract with you. In some cases, we may also have a legal obligation to collect Personal Data from you.
If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
Generally, we use the information (including Personal Data) we collect from or about Visitors and Clients, including without limitation, through technologies such as those described above primarily to provide better customer service to Clients, to improve and customize the content Visitors and Clients see, to help recognize Visitors and Clients when you use other devices, to provide the Services requested by Clients, and to contact Visitors and Clients about special promotions and new Services and for purposes including the following:
- to communicate directly with you and respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in the section below entitled Your Rights, Including Opt-Out Options;
- process transactions and send notices about Client agreements, the Services or a Client’s transactions;
- customize, measure, and improve our products, services and the content and delivery of our Services and Website(s);
- to send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies;
- To analyze trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole;
- compare information for accuracy and verify it with third parties;
- enable Visitors and Clients to post on our blogs and interact with GROWTHSTER through social media;
- perform data analyses (including market and consumer search, trend analysis, financial analysis and anonymization and aggregation of Personal Data).
- as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain; and
V. HOW WE SHARE THE DATA WE COLLECT
- Service providers under contract who help with parts of our business operations; (fraud prevention, bill collection, marketing, technology services, hosting services). For example, we may provide personal information to our service providers for direct emailing of our newsletters or notifications of our product/service offerings. The data shared can include name, job title, email address, message history, company information. All third parties are engaged under contract and obliged to meet appropriate security requirements and comply with all applicable legislation; Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Personal Data may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation) GROWTHSTER’s Social Media Pages. This information can appear in public ways, such as through search engines or other publicly available platforms, and can be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.
- We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
- Credit bureaus to report outstanding negative balance accounts, as allowed by law.
- We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets;
VI. HOW WE USE AND DISCLOSE OTHER INFORMATION
GROWTHSTER uses and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we would use or disclose it in the same way that we use and disclose Personal Data.
In some instances, we may combine Other Information with Personal Data (such as combining your name with the name of your organization). If that combination permits you to be identified, we will treat the combined information as Personal Data for as long as it is combined.
VII. WHERE AND HOW WE STORE, PROCESS AND PROTECT PERSONAL DATA
Personal Data collected is stored and processed on computers in the United States, Europe and other countries and we protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable US federal, state and EU or local laws and regulations.
We maintain adequate administrative, technical and physical safeguards designed to protect the Personal Data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
When processed as part of a hosted service, the information may be processed and stored on the servers of third party providers hired to provide the hosting, and our agreements with such parties require that they not use, disclose, or share such information except in line with Section V above.
Despite GROWTHSTER’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your Personal Data is limited to those who have a need to know. Those individuals who have access to the Personal Data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain Personal Data only for so long as the information is necessary to comply with an individual's request or until that person asks that the information be deleted, or as necessary for the performance of the Services to our Clients.
XII. YOUR RIGHTS, INCLUDING OPT-OUT OPTIONS
According to the GDPR, you have the rights:
- to access and rectify your data (to help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information);
- to opt-out of receiving marketing messages from GROWTHSTER at any time, free of charge by unsubscribing through the unsubscribe or opt-out link in an email, or by sending an email to email@example.com. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages.
- to be forgotten or to the erasure of your data, as well as to the restriction of processing of Personal Data (this may result in the inability to use the Services of GROWTHSTER or access certain of its websites);
- to retract your consent at any time to the process of your data;
- to portability of your data;
- to be informed, in case of automated decision-making process, of the logic underlying the system and the importance and consequences envisaged by the processing for the person concerned.
IX. SENSITIVE INFORMATION
We ask that you not send us or disclose any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.
X. CHANGES TO THIS PRIVACY NOTICE
XII. X. PRIVACY STATEMENT TO CALIFORNIA RESIDENTS
Under California Civil Code Section 1798.83, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Data, such as name, e-mail and mailing address including billing ZIP code and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at firstname.lastname@example.org.