Privacy Policy

This Website collects some Personal Data of its Users.

This document contains a section dedicated to California consumers and their privacy rights.

This document contains a section dedicated to Users residing in Brazil and their privacy rights.

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Owner and Data Controller

Growuz

Holder's contact email:  hello@growuz.com

Kinds of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address; Name; surnames); Web page; Tracker; Usage Data; country.

Complete information regarding each category of Personal Data that is collected is provided in the sections of this privacy policy dedicated to that purpose or through specific explanatory texts that are displayed before the collection of said Data.

Personal Data may be freely provided by the User or, in the case of Usage Data, will be collected automatically when using this Website.

All the Data requested by this Website are mandatory and the refusal to provide them may make it impossible for this Website to proceed with the provision of the Service. In cases where this Website specifically indicates that certain Data is not mandatory, Users are free not to communicate such Data without this having any consequence on the availability or operation of the Service. Users who have doubts about what Data is mandatory can contact the Owner.

The use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website is intended to provide the Service requested by the User, in addition to any other purposes that may be described in this document and in the Cookies Policy, if available.

The User assumes responsibility for the Personal Data of third parties that are obtained, published or shared through this Website and hereby declares that he has the consent of said third parties to provide said Data to the Owner.

Method and place of processing of the Data collected

Treatment Modalities

The Holder will treat the Data of the Users in an appropriate manner and will adopt the appropriate security measures to prevent unauthorized access, disclosure, alteration or destruction of the Data.

Data processing will be carried out using computers and/or IT tools, following organizational procedures and modalities strictly related to the stated purposes. In addition to the Owner, in some cases the Data may be accessed by certain categories of authorized persons, related to the operation of this Website (administration, sales, marketing, legal department and system administration) or external contractors who provide services to the Owner ( such as external providers of technical services, courier companies, hosting companies, IT companies, communication agencies) that will be appointed by the Owner as Treatment Managers, if necessary. An updated list of said persons may be requested from the Holder at any time.

Legal basis of the Treatment

The Owner may process the User's Personal Data, if one of the following conditions is met:

• When Users have given their consent for one or more specific purposes. Notice: Under several different laws, the Owner may be authorized to process Personal Data until the User objects to it ("opt-out"), without the need for consent or any other legal basis. However, this will not apply when the processing of Personal Data is subject to European regulations on the protection of Personal Data;
• When obtaining Data is necessary for the fulfillment of a contract between the User and/or any other pre-contractual obligation thereof;
• When the treatment is necessary for the fulfillment of a legal obligation that must be fulfilled by the User;
• When the treatment is related to a task carried out in the public interest or in the exercise of official powers granted to the Holder;
• When the treatment is necessary for the purpose of a legitimate interest pursued by the Owner or a third party.

In any case, the Holder is at your disposal to define the specific legal bases that apply to the treatment and in particular, if the collection of Personal Data is a contractual or statutory requirement or a necessary requirement to formalize a contract.

Place

The Data is processed in the offices of the Holder, as well as in any other place where the parties involved in said treatment process are located.
Depending on Users' location, Data transfers may involve the transfer of Users' Data to a country other than your own. For more information on the place of processing of such transferred Data, Users may refer to the section containing the details on the processing of Personal Data.

Users will also have the right to know the legal bases of Data transfers to another country outside the European Union or to any international organization that is governed by International Public Law or that is made up of two or more countries, such as the UN, and also know the security measures taken by the Owner to safeguard their Data.

In the event that such a transfer of Data takes place, Users may obtain more information by consulting the relevant sections of this document or requesting it from the Owner, through the contact information that appears in the contact section.

Storage period

Personal Data will be processed and kept for the time necessary and for the purpose for which they were collected.

Therefore:

• The Personal Data collected for the formalization of a contract between the Holder and the User must be kept as such until said contract has been fully formalized.
• The Personal Data collected in the legitimate interest of the Owner must be kept for the time necessary to fulfill said purpose. Users can find specific information related to the legitimate interest of the Owner by consulting the relevant sections of this document or by contacting the Owner.

The Holder may keep the Personal Data for an additional period when the User gives his consent to such treatment, provided that said consent remains in force. In addition, the Holder will be obliged to keep Personal Data for an additional period whenever it is required to comply with a legal obligation or by order from the authority.

Once the retention period has ended, the Personal Data must be deleted. Therefore, the rights of access, modification, rectification and data portability cannot be exercised once said period has expired.

Purpose of the Treatment of the Data collected

The Data relating to the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as for the following purposes: Contact management and sending messages, Contacting the User, Commenting on content, Viewing content from external platforms, Payment management, Protection against SPAM, Traffic optimization and distribution, Statistics, RSS feed management, Registration and authentication provided directly by this Website, Commercial affiliation, Content and functionality performance test (A/B testing) and Platform and hosting services.

Users can find specific information on the Personal Data used for each purpose in the section “Detailed Information on the Processing of Personal Data”.

Detailed information on the Treatment of Personal Data

Personal Data is collected for the following purposes and using the following services:

Additional information about Personal Data

The rights of the Users

Users may exercise certain rights regarding the processing of Data by the Owner.

Especially, Users have the right to do the following:

• Withdraw your consent at any time.  Users have the right to withdraw their consent when they have previously granted it for the processing of their Personal Data.
• Objection to the processing of your Data.  Users have the right to object to the processing of their Data if such processing is carried out on a legal basis other than consent. For more information, you can refer to the corresponding section below.
• Access to your Data.  Users have the right to know if their Data will be processed by the Owner, to obtain information on certain aspects of the treatment, in addition to obtaining a copy of the Data subject to treatment.
• Verify and request modification.  Users have the right to verify the accuracy of their Data and request that it be updated or corrected.
• Restrict the processing of your Data.  Users have the right, in certain cases, to restrict the processing of their Data. In this case, the Owner will process your Data for the sole purpose of storing them.
• Erase or remove Personal Data.  Users have the right, in certain cases, to obtain the elimination of their Data by the Owner.
• Receive your Data and transfer it to another person in charge.  Users have the right to receive their Data in a standard, structured, mechanically readable format and, if technically possible, to have it transferred to another person in charge without any impediment. This provision will be applicable provided that the Data has been processed through automated means and that the processing is based on the User's consent, on a contract to which the User is a party or that appears in the pre-contractual obligations thereof.
• Make a complaint.  Users have the right to file a claim with the competent authority for the protection of personal data.

Details on the right to object to treatment

When the processing of Personal Data is of public interest, in the exercise of official powers granted to the Holder or due to a legitimate interest of the Holder, Users may oppose said treatment explaining a reason in relation to their particular situation to justify their objection.

Users should know that, however, if their Personal Data is processed for commercial purposes, they may object at any time to such processing without the need for justification. In order to know if the Personal Data of the Users is being processed by the Holder for commercial purposes, they should consult the relevant sections of this document.

How to exercise these rights

Any request to exercise the rights of the User can be addressed to the Owner through the contact information provided in this document. These requests will be processed by the Holder free of charge as soon as possible and always within a period of one month.

Additional information on the collection of Data and its treatment

Legal defense

The User's Personal Data may be used for the legal defense of the Owner before a court or in the judicial phases prior to a possible lawsuit arising from the inappropriate use of this Website or the related Services.

The User declares to know that the Holder may be required by public authorities in order to reveal Personal Data.

Additional information about the User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services or the collection and processing of Personal Data.

System log and maintenance

For reasons related to operation and maintenance, this Website and any other service, provided by third parties, that is used, may collect a system log; that is, files that record the interaction with this Website and that may contain Personal Data, such as the User's IP address.

Information not contained in this privacy policy

Additional information on the collection and processing of Personal Data may be requested from the Owner at any time. Contact information is indicated at the beginning of this document.

How “Do Not Track” requests are processed

This Website does not allow “Do Not Track” requests.
To determine whether any of the third-party services you use accept "Do Not Track" requests, please review their privacy policies.

Modification of this privacy policy

The Owner reserves the right to modify this privacy policy at any time, notifying Users through this page and, if possible, through this Website and/or if technically and legally possible, notifying users directly. Users, in case the Holder has the necessary contact information for this purpose. It is strongly recommended that you check this page frequently, referring to the date of the last update indicated at the bottom of the page.

In the event that the changes affect the treatment activities carried out based on the User's consent, the Owner must obtain, if necessary, the User's new consent.

Information for California Consumers

This part of this document is integrated with the information contained in the rest of the privacy policy and complements it, and is provided by the company that operates this Website and, where appropriate, by its parent company, subsidiaries and affiliated companies (which , for the purposes of this section, will be collectively referred to as “we”, “our” or “our”).

The provisions contained in this section are applicable to any User who is a consumer residing in the State of California, United States of America, in accordance with the “California Consumer Privacy Act of 2018” ) (the Users will be referred to hereinafter collectively simply as "You", "yours", "yours"), and, for said consumers, these provisions replace any other provisions that may be contrary to the provisions contained in the policy of privacy or that conflict with them.

This part of this document uses the term “personal information” as defined in the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we have collected, disclosed or sold and the purposes for which such actions are taken. You can read about these activities in detail in the section entitled “Detailed Information on the Processing of Personal Data” that appears in this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers and Internet information.

We will not collect additional categories of personal information without notifying you.

How is the information collected: what are the sources of the personal information we collect?

We collect the above categories of personal information from you, either directly or indirectly, when you use this Website.

For example, you directly provide us with your personal information when you make requests through any form on this Website. You also provide us with personal information indirectly when you browse this Website, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who collaborate with us in connection with the Service or the operation of this Website and its functionalities.

How we use the information we collect: sharing and disclosure of your personal information to third parties for business purposes

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter into a written contract with such third party that requires the recipient to keep the personal information confidential and not use it for any other purpose or purposes other than those necessary for the performance of the contract.

We may also disclose your personal information to third parties when you request or expressly authorize us to do so, in order to provide our Service to you.

For more information on the purposes of the treatment, please consult the relevant section of this document.

Sale of your personal information

For our purposes, the term “sale” means any “sale, lease, disclosure, disclosure, dissemination, making available, transfer or communication by any other means, whether orally or in writing, or by electronic means, of the personal information of a consumer by the company to another company or a third party, in exchange for a monetary or economic consideration of any other type”.

This means that, for example, a sale can occur every time an application displays advertisements, or performs statistical analysis of its traffic or views, or simply because it uses tools such as social network plugins or the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you ask us to stop selling your data, we will comply with your request.

Such requests may be made freely, at any time, without the need to submit a verifiable request, simply by following the instructions provided below.

Instructions for opting out of the sale of personal information

If you wish to obtain more information, or exercise your right of disqualification regarding any of the sales made through this Website, both online and offline, you can contact us so that we can provide you with additional information, using the contact information provided in the this document.

What are the purposes for which we use your personal information?

We may use your personal information to enable the operational operation of this Website and its features (“business purposes”). In such cases, your personal information will be processed in a way that is necessary and proportionate for the business purpose for which it was collected and strictly within the limits of the compatible operational purposes.

We may also use your personal information for other reasons, such as business purposes (as indicated in the “Detailed Information on the Processing of Personal Data” section in this document), as well as for compliance with laws and the defense of our rights. rights before the competent authorities when our rights and interests are threatened or we suffer effective damage.

We will not use your personal information for different, unrelated or incompatible purposes without notifying you.

Your California Privacy Rights and How to Exercise Them

Right to know and portability

You have the right to request that we disclose to you:

• the categories and sources of personal information we have collected about you, the purposes for which we use your information and with whom that information is shared;
• in case of sale of personal information or disclosure for business purposes, two lists in which we will disclose:
  • for sales, the categories of personal information acquired by each category of recipient; Y
  • for disclosures for business purposes, the categories of personal information obtained by each category of recipient.

The disclosure described above will be limited to personal information collected or used in the last 12 months.

If we provide our response electronically, the information included will be “portable”, meaning it will be delivered in a readily usable format that allows you to transmit the information to another entity without hindrance – provided that this is technically feasible.

Right to request the deletion of your personal information

You have the right to request that we delete any personal information about you, without prejudice to the exceptions established by law (such as, without limitation, when the information is used to identify and repair errors on this Website, to detect incidents of security and protect ourselves against fraudulent or illegal activities, to exercise certain rights, etc.).

If no legal exception applies, as a result of exercising your right we will delete your personal information and order all our service providers to do the same.

How to exercise your rights

To exercise the rights described above, you must submit a verifiable request to us by contacting us using the contact details provided herein.

In order for us to respond to your request, we must know who you are. Therefore, you can only exercise the aforementioned rights by making a verifiable request that must:

• provide enough information so that we can reasonably verify that you are the person whose personal information we have collected or an authorized representative;
• describe your request in sufficient detail so that we can properly understand, evaluate and respond to it.

We will not respond to any request if we cannot verify your identity and therefore confirm that the personal information in our possession relates to you.

If you are unable to personally submit a verifiable application, you may authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you may make a verifiable request on behalf of a minor subject to your custody.

You can submit a maximum of 2 applications within a 12-month period.

How and when we are expected to process your request

We will confirm receipt of your verifiable request within 10 days and provide information on how we will process your request.

We will respond to your request within 45 days of receipt. In the event that we need more time, we will explain the reasons why this is necessary and how much additional time we will need. In this regard, please note that the fulfillment of your request may take us up to a maximum of 90 days.

Our disclosure(s) will be for the immediately preceding 12-month period.

If we deny your request, we will explain the reason for our denial.

We do not charge any fees to process or respond to your verifiable request, unless such request is manifestly unfounded or excessive. In such cases, we may charge you a reasonable fee or refuse to execute the request. In either case, we will inform you of your choices and explain the reasons for them.

Information for Users residing in Brazil

This part of this document is integrated with the information contained in the rest of the privacy policy and complements it, and is provided by the company that operates this Website and, where appropriate, its parent company, subsidiaries and affiliated companies (to which purposes of this section will be collectively referred to as “we”, “our” or “our”).
The provisions that appear in this section are applicable to all Users residing in Brazil, in accordance with the “Lei Geral de Proteção de Dados” (hereinafter we will refer to Users simply as “you”, “yours” or "its"). For said Users, these provisions replace any other provisions that may be contrary to the provisions contained in the privacy policy or that conflict with them.
This part of this document uses the term “Personal Information” as defined in the Lei Geral de Proteção de Dados ( LGPD ).

Reasons why we process your personal information

We can only process your personal information if we have a legal basis for such processing. The legal bases are the following:

• Your consent to the relevant processing activities;
• The fulfillment of a legal or regulatory obligation that concerns us;
• The application of public policies established in laws or regulations or based on contracts, agreements and similar legal documents;
• The carrying out of studies by entities dedicated to research, preferably carried out on the basis of anonymized personal information;
• The execution of a contract and its pre-contractual measures, in cases where you are a party to said contract;
• The exercise of our rights in judicial, administrative or arbitration proceedings;
• The protection or physical security, either of you or of a third party;
• Health protection – in procedures carried out by health organizations or professionals;
• Our legitimate interests, provided that your fundamental rights and freedoms do not override those interests; Y
• credit protection.

For more information about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out which categories of your personal information are processed, you can read the section entitled “Detailed information on the Processing of Personal Data” that appears in this document.

Why we treat your personal information

To find out why we process your personal information, you can read the sections entitled "Detailed information on the Processing of Personal Data" and "Purpose of the Processing of the Data collected" that appear in this document.

Your privacy rights in Brazil, how to make a request and our response to your requests

Your privacy rights in Brazil

You have the right to:

• Obtain a confirmation of the existence of activities of treatment of your personal information;
• Access your personal information;
• Have incomplete, inaccurate, or out-of-date personal information rectified;
• Obtain the anonymization, blocking or deletion of your unnecessary or excessive personal information, or information that is not being treated in accordance with the LGPD;
• Obtain information about the possibility of giving or withholding your consent and the consequences of such actions;
• Obtain information about the third parties with whom we share your personal information;
• Obtain, upon your express request, the portability of your personal information (except anonymized information) to another provider of services or products, as long as our commercial and industrial secrets are protected;
• Achieve the elimination of your personal information that is being processed if the processing was based on your consent, except if one or more exceptions provided for in art. 16 of the LGPD;
• Revoke your consent at any time;
• Submit a complaint regarding your personal information to the ANPD (the National Data Protection Authority) or to consumer protection agencies;
• Oppose a treatment activity in cases in which the treatment is not carried out in accordance with the provisions of the law;
• Request clear and adequate information on the criteria and procedures used for an automated decision; Y
• Request the review of decisions made solely on the basis of the automated processing of your personal information and that affect your interests. This includes decisions that define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against or suffer any other type of prejudice if you exercise your rights.

How to apply

You can submit your express request to exercise your rights at no cost, at any time, using the contact information provided in this document or through your legal representative.

How and when we will respond to your request

We will endeavor to respond promptly to your requests.
In any case, if we are unable to do so, we will make sure to inform you of the factual or legal reasons that prevent us from granting your requests immediately or even completely. In the cases in which we are not processing your personal information, we will indicate the natural or legal person to whom you should direct your requests, if we are in a position to do so.

In the event that you submit a request for  access  or  confirmation of the processing  of personal information, please be sure to specify whether you want your personal information to be delivered in electronic or printed format.
You will also need to tell us if you want us to respond to your request immediately, in which case we will do so in a simplified way, or if you need a full statement instead.
In the latter case, we will respond within 15 days from the time of your request, providing you with all the information about the origin of your personal information, confirmation of whether or not there are records, any criteria used in the treatment and the purposes of treatment, while protecting our commercial and industrial secrets.

In the event that you submit a request to  rectify, delete, anonymize or block personal information , we will ensure that we immediately communicate your request to other parties with whom we have shared your personal information in order to allow those third parties to also comply with your request – except in cases where such communication is impossible or requires a disproportionate effort on our part.

Transfers of personal information outside of Brazil permitted by law

We are allowed to transfer your personal information outside the territory of Brazil in the following cases:

• When the transfer is necessary for international legal cooperation between public intelligence, investigative and judicial bodies, in accordance with the legal means established in international law;
• When the transfer is necessary to protect your life or physical safety or that of a third party;
• When the transfer is authorized by the ANPD;
• When the transfer is derived from a commitment assumed in an international cooperation agreement;
• When the transfer is necessary for the fulfillment of a public policy or a legal attribution of a public service;
• When the transfer is necessary for the fulfillment of a legal or regulatory obligation, the execution of a contract or its pre-contractual measures, or the ordinary exercise of rights in judicial, administrative or arbitration proceedings.

Last revision: August 07, 2022

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