Who we are
Our website address is https://www.growlity.com
1. Introduction
This privacy policy notice provides you with details of how we collect and process your personal and organizational data.
Growlity Inc. collects and holds personal and organizational information from clients, customers, employees, contractors, and other individuals. Growlity Inc. collects and holds this information when it is necessary for business purposes. The personal and organizational information Growlity Inc. collects and holds relates to the contact details and organizational roles of our clients, suppliers and other business contacts. Generally, this information includes client logo, names, addresses, telephone numbers, e-mail addresses, testimonials and job titles.
This transaction when done over the electronic information exchange requires Growlity Inc. to obtain payment information. Upon completion of the transaction, the payment details are shredded. Growlity Inc. collects most information directly from individuals when Growlity Inc. deal with them. The personal and organizational information Growlity Inc. collect may be provided in forms filled out by individuals, face to face meetings, email messages, consulting assignment documentation, telephone conversations, or by third parties. If you contact us, we may keep a record of that contact.
Our email address is [email protected]
Our postal address is 30 N GOULD ST STE R, SHERIDAN, WY 82801, USA.
If you believe that information we hold about you is incorrect or out of date, or if you have concerns about how we are handling your personal and organizational information, please contact us at [email protected] and we will try to resolve those concerns. If you wish to have your personal and organizational information deleted, please contact us at [email protected] and we will take reasonable steps to delete it (unless we need to keep it for legal, promotional or auditing purposes.)
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offenses.
2. How we use your Personal Data
We will only use your personal and organizational data when legally permitted. The most common uses of your personal and organizational data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via featuring it on our website, email or text message. You have the right to withdraw consent to marketing or promotional activities at any time by emailing us at [email protected]
Purposes for Processing your Personal Data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
Purpose/Activity | Type of Data | Lawful basis for Processing |
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business |
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of business reorganization or group restructuring exercise (b) Necessary to comply with a legal obligation |
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests to develop our products/services and grow our business |
Marketing Communications, featuring or promoting your business logo and testimonial on our website
You will receive marketing communications including featuring or promoting your business name, logo and testimonial related information from us assuming you have:
- requested information from us or services from us; or
- you have successfully taken our services at any point of time
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at [email protected] at any time. Where you opt-out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
3. Disclosures of your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Regulators and other authorities at our local presence and other relevant jurisdictions require reporting of processing activities in certain circumstances.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
- To keep clients and other contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings, seminars, and other events we are holding
- To maintain contact with clients
- For purposes related to the employment of our personnel and providing internal services to our staff
- For recruitment purposes
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
4. International Transfers
Growlity Inc. has offices in the United State of America and serving clients worldwide with Virtual Consulting and Coaching services to improve the business performance of the clients. As part of Growlity Inc. business operations exchanges of information may occur, including personal information, between Growlity Inc.’s international alliance of the service providers. As a result, we may transfer personal information outside the USA to countries whose privacy laws do not provide the same level of protection as the USA’s. Growlity Inc. may also use overseas facilities or contractors to process or back-up our information or to provide certain services to us. As a result, we or another Growlity Inc. international representative may transfer your personal information to our overseas professionals for these purposes.
However, any such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.
Privacy on our Websites and Applications
This policy also applies to any personal information we collect via our websites, including growlity.com and applications including mobile applications. In addition to the personal information you provide to us directly (such as where you make a request or complete a registration form), Growlity Inc. may also collect personal information from you via its applications and websites.
Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.
Users may opt-out of Google’s use of cookies by visiting the Google advertising opt-out page. Alternatively, you can opt-out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative. We use cookies for the purposes of conducting re-marketing Campaigns. Google’s Display Network uses the DoubleClick Cookie. You can opt-out of DoubleClick cookies by visiting the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.
In order to properly manage our websites and applications, we may log certain statistics about the users of the facilities, for example, the users’ domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our websites and applications present the best possible navigational experience for users.
As Growlity Inc. wants your user experience to be as informative and resourceful as possible, we provide a number of links to websites and embedded content operated by third parties that may also set cookies. Growlity Inc. is not responsible for the privacy practices or policies of those sites. We encourage you to review each website’s privacy policy, especially if you intend to disclose any personal information via that site. A link to another non-Growlity Inc. website is not an express or implied endorsement, promotion, or warranty of the products or services offered by or accessible through that site or advertised on that site.
If you are located in the European Economic Area, you need to be aware that we share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5. Data Security
Growlity Inc. has put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Growlity Inc. has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. Data Retention
Growlity Inc. will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. Your Legal Rights
Under certain circumstances, you have the right under data protection laws to your personal data. These include the right to:
- Request access to your personal data.
- Request the correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request the transfer of your personal data.
- The right to withdraw consent.
Since Growlity Inc. is a GDPR compliant global organization, we have very strong and effective control implemented for all our business processes to take care of data privacy. You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at [email protected]
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Growlity Inc. may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Growlity Inc. may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.