Privacy Policy

We collect identifiers (such as name, email, postal address, and IP address), commercial information, internet or other network activity, geolocation, characteristics of protected classifications such as gender and age, and inferences drawn from that information. We collect it from you and from service providers, advertising partners, and data providers.

We use it to operate Grow Discover, provide rewards, secure accounts, and advertise, including Tailored Advertising. We may sell personal information and share it for cross-context behavioral advertising, as described below. We keep it only as long as reasonably necessary for the purposes in this policy. California residents can opt out of sale and sharing and can request access, correction, or deletion by emailing greg@growbrand.co.

Grow Discover offers points and other rewards for attending eligible meetings, events, or activities and for other participation described in the app. Those rewards are a financial incentive under the California Consumer Privacy Act because participation involves the collection, retention, and use of personal information.

The incentive is the points, benefits, offers, and cash equivalents described in the app and in our Terms of Service. Rewards may expire and may be forfeited if your account is closed.

The personal information implicated includes identifiers, commercial information, internet or other network activity, geolocation, and inferences.

You opt in by creating an account and participating. You may withdraw at any time by emailing greg@growbrand.co or by closing your account. If you withdraw, you may stop earning rewards and you may lose unused rewards.

We set the incentive so that it is reasonably related to the value of your personal information to the Program. We estimate that value in good faith from the cost of providing the reward and from the use of participation data to operate the Program, match members with sponsors, and administer rewards. Email greg@growbrand.co to request the current good-faith estimate and the method used to calculate it.

• Session Cookies. We use session cookies to operate our Site, for security purposes, and to customize our users' experiences.
• Persistent Cookies. We use persistent cookies to remember your preferences and other information, including products you may be interested in, and various settings, and to customize our users' experience. Cookies are often used in conjunction with other technologies to understand online behavior. For example, GROW uses cookies in conjunction with pixels, which are small sections of code that we may place on our Site, to associate particular online activities to a browser or device (e.g., to understand that a browser or device has visited a specific page of our Site and/or to understand the total number of unique users that have visited a specific page of our Site).

We use session cookies in connection with our Site, for security purposes, and to provide you with customizations of your experience, such as highlighting your recently viewed items, to detect and remember your region and language preferences, and track your activities on our Site. We use persistent cookies to ensure that you are directed to the correct regional version of our Site, to remember items you may have put in your "Cart", in connection with "Tailored Advertising" (which associates a user's activity and interest information, demographic information, geographic information, and similar information with a browser cookie or other online identifier in order to provide more useful and relevant advertising), and for other customization purposes. We may use the services of third-party providers in connection with our use of cookies.

None of these cookies is strictly necessary to access our Site. You may set your browser to refuse all cookies or to indicate when a cookie is being set. However, if you do not accept cookies, parts of our Site may function differently and you may not be able to use some portions or features of our Site. For more information about how to manage your cookies and your cookie preferences, please use the "help" menu of your web browser or explore the customer support sections of your web browser. To "opt out" of Tailored Advertising, please see the "Your Choices: Opt-Out/Right to Withdraw Consent" section below.

We also collect certain additional passive tracking data concerning your device and how you access and use our Site ("Usage Data"). This Usage Data includes information such as your computer's Internet Protocol ("IP") address, browser type, and browser version, as well as the pages of our Site that you visit, the times and dates of your visits, the time spent on, and interactions with, those pages, location data, and diagnostic data. You can enable or disable location services when you use our Site at any time, through your device settings.

We may use third-party technology providers to monitor and analyze the use of our Site. This includes Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

GROW uses third-party services to advertise our products and services to you after you visit our Site. We and our third-party vendors use cookies and other online tracking technologies on our Site and in third-party services (including in emails and advertisements and on other digital properties) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant Tailored Advertising and/or other content to you and others on our Site and in third-party services or third-party digital properties after you have left our Site. In addition to the use of such online tracking technologies, we may also upload customer lists (including email addresses) to third-party service providers, such as Facebook and Google, to have customized ads served to people (or people similar to people) who have visited our Site ("Matched Ads"). "Matched Ads" may be considered a kind of Tailored Advertising.

Unsubscribe / right to withdraw consent

If you do not want us to contact you or send you information by email, postal mail and/or telephone, or if you would like to change any of the information that you have previously provided to us, please let us know by emailing us at greg@growbrand.co. You may also unsubscribe from receiving our newsletters, marketing and promotional materials by following the unsubscribe link in our marketing and promotional emails or the instructions provided in any other communication we send.

Opt-out / right to withdraw consent

You may refuse or remove persistent targeting cookies by "opting out" of "interest-based advertising" / "online behavioral advertising" / Tailored Advertising via third-party advertising cookies at the following websites:

• http://www.aboutads.info/choices
• http://youradchoices.ca/choices
• Youronlinechoices.com (by clicking the "Your ad choices" link after selecting the appropriate country)
• Adjusting your browser settings to refuse or remove cookies.

Please note that you need to configure each browser on each device that you use if you wish to opt-out or block some or all cookies for that browser. If you buy a new device, upgrade or change web browsers or delete your opt-out cookies, you will need to perform the applicable opt-out process again. In order for opt-out processes to work, your browser must be set to accept third-party cookies. Additional information about cookies is available at https://youradchoices.com/choices-faq and www.youronlinechoices.com (by clicking the "Frequently Asked Questions" / "FAQs" link after selecting the appropriate country).

You may also "opt out" of "interest-based advertising" / "online behavioral advertising" / Tailored Advertising in mobile application environments via the privacy settings on your mobile device, including by selecting "Limit Ad Tracking" in such privacy settings. Selecting such setting will result in the elimination of Tailored Advertising via the applicable mobile advertising ID (e.g., Apple IDFA or Google Advertising ID) on that mobile device.

In addition, you may opt-out of Matched Ads via your email address by following the unsubscribe link in our marketing and promotional emails or by emailing us at greg@growbrand.co. Please note that there may be a slight delay between your unsubscribe and/or Matched Ads email opt-out elections and the processing of such elections. Please also note that we are not responsible for third parties' failure to comply with opt-out instructions.

We use the information we collect for our operational and commercial purposes, including:

• Product, Service, and Contract Fulfillment (including to manage, perform, and administer our contracts)
• Customer Support (including to manage and administer our relationships with our customers and potential customers, and to maintain and improve the experiences of our customers and potential customers)
• Quality Assurance and Supply Chain Management (including to assist in buying decisions)
• Site Performance and Administration (including to measure the number of visitors to different sections and pages of our Site, to determine how best to enhance the usability and performance of our Site, and to detect and prevent fraud)
• Marketing and Advertising (to send marketing information about our products and services to consumers, and to engage in advertising, including Tailored Advertising)
• Other Communications with Customers
• Internal Financial, Employment, and Administrative Purposes
• Compliance with Legal/Regulatory Obligations

GROW will retain your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy. The criteria used to determine the retention periods include:

• How long the personal information is needed to provide the services (including in connection with our guarantees) and operate the business;
• The type of personal information collected; and
• Whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

GROW will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction, in jurisdictions where the data protection laws may differ than those from your jurisdiction. If you are located outside of the United States and provide information to us, please note that such information, including personal data, may be sent to, and processed in, the United States and/or other countries. By providing us with your personal data, you consent to such transfers to and subsequent processing in such countries (including the United States), which your country may not consider to provide for adequate privacy protections. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

We may share your information with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing payments, providing customer service and marketing assistance, performing business and sales analysis, supporting our Site functionality and supporting other features offered through our Site, and providing advertising and marketing services (including delivering Tailored Advertising and email marketing campaigns, and analyzing and improving the effectiveness of our advertising and marketing). These service providers may have access to personal information needed to perform their functions and are generally not permitted to share or use non-aggregated personal information for any other purposes. We may also share your personal information with GROW affiliates. In addition, unless you are a European Economic Area (which includes, for purposes of this Privacy Policy, Switzerland and the United Kingdom) ("EEA") data subject, we may share your personal information with third-party advertising, marketing, and data service companies in connection with our use of their data cooperative and data enrichment, verification, and analytics products and services, which sharing may constitute a "sale" under the California Consumer Privacy Act (CCPA).

Under certain circumstances, GROW may be required to disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

GROW will disclose your information in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of GROW
• To prevent or investigate possible wrongdoing in connection with our Site
• To protect the personal safety of users of our Site or the public
• To protect against legal liability

Data security is important to us, but please keep in mind that no method of transmission over the Internet or method of electronic storage or transmission is 100% secure. While we strive to use reasonable and appropriate means to protect information, we cannot guarantee its absolute security. We do and will take reasonable and appropriate steps designed to ensure that your data is treated securely and in accordance with this Privacy Policy, and we will not transfer your personal data to an organization or a country unless there are adequate controls in place, including with respect to the security of your personal data.

We do not support browser "Do Not Track" (DNT) signals, and do not change any of our data collection or use practices when we receive such signals. Do Not Track is a preference you can set in your web browser. We will continue to evaluate potential responses to "Do Not Track" signals in light of industry developments or legal changes.

We are committed to honoring your privacy choices. For more information, please see the "Your Choices" section above.

If you are an individual who is a resident of California (a California "consumer"), you have the following rights under the California Consumer Privacy Act, which went into effect on January 1, 2020, with respect to your "personal information" (as defined by CCPA):

Right to know

You have the right to request that we disclose to you, following your "verifiable consumer request":

• The categories of personal information we have collected about you
• The categories of sources from which the personal information is collected
• The business or commercial purpose for collecting personal information
• The categories of third parties with which we share personal information
• The specific pieces of personal information we have collected about you
• The categories of personal information about you that we disclosed for a business purpose

If we sell your personal information:

• The categories of personal information that we sold about you
• The categories of third parties to which your personal information was sold, by category or categories of personal information for each category of third parties to which the personal information was sold
• The business or commercial purpose for selling personal information

Right to delete

You have the right to request that we delete, following your "verifiable consumer request", the specific pieces of personal information we have collected about you. That request can cover the categories of personal information we collect, the specific pieces of personal information we have collected about you, and the categories of sources from which we collect personal information.

Right to correct

You have the right to request that we correct inaccurate personal information we maintain about you, subject to verification of your request.

Right to opt out of sale and sharing

You have the right, at any time, to direct us not to sell your personal information or share it for cross-context behavioral advertising. Tailored Advertising and Matched Ads may be a "share" under California law. This right is different from the right to "opt out" of "interest-based advertising" / "online behavioral advertising" / Tailored Advertising described above under "Your Choices: Opt-Out/Right to Withdraw Consent". You may use either method.

Right to limit use of sensitive personal information

Geolocation may include precise geolocation, which is sensitive personal information under California law. You may direct us to limit our use of sensitive personal information to what is necessary to provide the Program, secure it, and perform the other purposes permitted by California law. Email greg@growbrand.co to make that request. You can also turn location services off in your device settings.

Right to non-discrimination

We may not discriminate against you because you exercise any of your rights under CCPA, including by:

• Denying goods or services to you
• Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to you
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

The process we currently use to verify "requests to know" and "requests to delete" requires you to provide your email address, your postal address, and information about your GROW purchase history.

Disclosures for a Business Purpose: We disclose (and during the last 12 months have disclosed) each of the above categories of personal information for a business purpose with our authorized service providers that perform certain services on our behalf, including fulfillment, shipping, and handling providers, payment service providers, data analytics providers, technology service providers, and advertising and marketing service providers and platforms. These services may include fulfilling orders, processing credit card payments, providing customer service and marketing assistance, performing business and sales analysis, supporting our Site functionality and supporting other features offered through our Site, and providing advertising and marketing services (including delivering Tailored Advertising and email marketing campaigns, and analyzing and improving the effectiveness of our advertising and marketing).

"Sales": We "sell" (as defined by CCPA) (and during the last 12 months have sold) each of the above categories of personal information (other than "Inferences") to advertising, marketing, and data service companies in connection with our, their, and their respective customers' marketing, advertising, and other business and commercial activities (in connection with our use and/or their provision of their data cooperative and data provision, enrichment, verification, and analytics products and services). As of September 1, 2020, we resumed our sharing of personal information of California consumers with third-party data cooperative companies in connection with our use of their products and services; we previously shared such personal information with those companies prior to January 1, 2020, but ceased such sharing between January 1, 2020 and August 31, 2020. However, we do not knowingly sell the personal information of California consumers under the age of 16 without required affirmative authorization. If you are a California consumer, you have the right, at any time, to direct us not to sell your personal information or share it for cross-context behavioral advertising. You may exercise that right by emailing greg@growbrand.co, or by any of the other methods described under Methods of submitting requests.

Do not sell or share my personal information

If you are a California consumer, you may submit requests to know, correct, or delete personal information, to opt out of sale and sharing, or to limit the use of sensitive personal information, by email to greg@growbrand.co.

We will maintain records of consumer requests made under CCPA and how we responded to those requests in accordance with CCPA.

If you are a California consumer, you may use an "authorized agent" (as defined by CCPA) to submit requests to exercise your "right to know", your "right to delete" and/or your "right to opt-out" on your behalf under CCPA. Your authorized agent will need to provide us with a copy of a written permission that is signed by you and indicates that you have provided such authorization.

We collect (and during the last 12 months have collected) the following categories of personal information, from the following categories of sources, and for the following business or commercial purposes.

Identifiers

Identifiers (such as a real name, postal address, email address, an online identifier, or an internet protocol address). We receive such information directly from consumers (such as when they complete a purchase on our Site) and/or from third-party vendors (such as vendors that use cookies and other online tracking technologies on our Site and in third-party services, including in emails and advertisements, and third-party data providers). We use it for our operational and commercial purposes, including (i) managing, performing, and administering our contracts and relationships with consumers, (ii) sending information (including marketing information about our products) to consumers, (iii) engaging in Tailored Advertising, and (iv) selling such personal information to advertising, marketing, and data service companies (in connection with our use of their data cooperative and data provision, enrichment, verification, and analytics products and services).

Protected classifications

Characteristics of protected classifications under California or federal law (such as gender and age). We receive such information from third-party vendors, including vendors that perform analytics and Tailored Advertising services for us and third-party data providers. We use it for our operational and commercial purposes, including engaging in Tailored Advertising and selling such personal information to advertising, marketing, and data service companies (in connection with our use of their data cooperative and data provision, enrichment, verification, and analytics products and services).

Commercial information

Commercial information (such as records of the products a consumer purchased). We receive such information directly from consumers (based on the purchase activities of those consumers on our Site) and/or from third-party vendors (such as third-party data providers). We use it for our operational and commercial purposes, including:

• managing our supply chain (including with respect to buying decisions),
• managing, performing, and administering our contracts and relationships with consumers,
• engaging in Tailored Advertising, and
• selling such personal information to advertising, marketing, and data service companies (in connection with our use of their data cooperative and data provision, enrichment, verification, and analytics products and services).

Internet or other electronic network activity

Internet or other electronic network activity information (such as browsing history, search history, and information regarding interactions with our Site and our advertising). We receive such information from third-party vendors, including ad platforms and vendors that use cookies and other online tracking technologies on our Site and in third-party services (including in emails and advertisements). We use it for our operational and commercial purposes, including:

• managing our supply chain (including with respect to buying decisions),
• engaging in Tailored Advertising, and
• selling such personal information to advertising, marketing, and data service companies (in connection with our use of their data cooperative and data provision, enrichment, verification, and analytics products and services).

Geolocation data

We receive geolocation data directly from consumers (such as when they complete a purchase on our Site) or from third-party vendors (such as third-party data providers). We use it for our operational and commercial purposes, including:

• managing, performing, and administering our contracts and relationships with consumers,
• sending information (including marketing information about our products) to consumers, and
• selling such personal information to advertising, marketing, and data service companies (in connection with our use of their data cooperative and data provision, enrichment, verification, and analytics products and services).

Inferences

Inferences drawn from any of the other categories of personal information to create a profile about a consumer reflecting, for example, a consumer's product preferences. We receive such information from third-party vendors, including vendors that perform analytics and remarketing services for us. We use it for our operational and commercial purposes, including to engage in Tailored Advertising.

Joingrow.com is committed to providing a website that is accessible to the widest possible audience, regardless of technology or ability. We are actively working to increase the accessibility and usability of our website and in doing so adhere to many of the available standards and guidelines.

Joingrow.com is compatible with most major Internet browsers including Chrome, FireFox, and Safari and may not perform optimally on Internet Explorer and older browser versions.

Joingrow.com engages in regular automated testing and (annual / bi-annual) manual audits and user testing to assess and improve accessibility.

We welcome your feedback on your experience with joingrow.com. Email us at annabel@joingrow.com with any questions or comments you have.

California's "Shine The Light" law permits certain individuals who are California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties for their direct marketing without your consent, except as provided for in this Privacy Policy.

For more information, please email us at greg@growbrand.co, with "California Shine the Light Privacy Request" in the subject line, and your full name, email address, postal address and specific services you have used in the body of your email.

Legal bases

The EU General Data Protection Regulation requires a "legal basis" for processing "personal data" (as defined by GDPR) of EEA data subjects. If you are an EEA data subject, GROW's legal basis for collecting, using, and disclosing the "personal data" described in this Privacy Policy will depend on the personal data we collect, the specific context in which we collect it, and the specific purposes for which we collect and use it, including as follows:

• To respond to requests and questions, including about our products. Such responses may be necessary to manage and perform our contracts (including our Terms and Conditions) with the applicable data subject or to take steps at the request of the data subject prior to entering into a contract. In addition, we have a legitimate interest in managing our relationships with our customers and potential customers and to ensure that we are as effective and efficient as we can be and that we optimize the experience and satisfaction of our customers.
• To provide customer support. Such support may be necessary to manage and perform our contracts (including our Terms and Conditions) with the applicable data subject or to take steps at the request of the data subject prior to entering into a contract. In addition, we have a legitimate interest in providing customer support and in optimizing the experience and satisfaction of our customers.
• To provide goods and services to our customers, and otherwise to perform our contracts with our customers. To manage and perform our contracts (including our Terms and Conditions) with the applicable data subject.
• To provide, maintain, administer, improve and customize our Site. We have a legitimate interest in maintaining and improving the quality and efficiency of the products and services offered to our customers and potential customers, and in optimizing the experience and satisfaction of our customers.
• The day-to-day running and management of our business and the products and services offered to customers. We have a legitimate interest in managing our business, including for operational purposes, such as supply chain management (including with respect to buying decisions) and financial, employment, and administrative decision-making.
• For fraud prevention and detection and other security purposes. We have a legitimate interest in preventing and detecting fraud, especially in connection with our Site and our products and services.
• In response to diligence investigation inquiries by third parties that are evaluating the prospect of acquiring all or part of our business, assets, or shares, or that succeed us in carrying on our business. We have a legitimate interest in managing our business, including for operational, financial, employment, and administrative purposes.
• To enforce or defend our rights. To manage and perform our contracts (including our Terms and Conditions) with the applicable data subject and, if applicable, to comply with our legal or regulatory obligations.
• To investigate, manage, and resolve complaints and claims. To manage and perform our contracts (including our Terms and Conditions) with the applicable data subject and, if applicable, to comply with our legal or regulatory obligations.
• To investigate, manage, and resolve regulatory matters, investigations, and claims. To comply with our legal or regulatory obligations.
• To share data with police, law enforcement, tax authorities or other government agencies where we have a legal obligation and to comply with applicable laws, regulations or codes of practice. To comply with our legal or regulatory obligations.
• To allow you to participate in interactive features of our Site when you choose to do so. With your consent, if required by applicable law.
• For marketing and advertising, including Tailored Advertising. With your consent, if required by applicable law. If you no longer wish to consent to Tailored Advertising, you can withdraw your consent at any time (please see the "Your Choices: Opt-Out/Right to Withdraw Consent" section above). If you wish to stop receiving marketing communications from us, you can unsubscribe by following the unsubscribe link in our marketing and promotional emails or the instructions provided in any other communication we send.

Information required for the Program

Account information is required to enter into and perform our contract with you. If you do not provide it, we cannot create your account or provide the Program. Marketing messages are optional. You can withdraw consent for marketing and Tailored Advertising as described in Your Choices.

We draw inferences for advertising and to operate the Program. You can object to profiling related to direct marketing as described below.

Your rights under GDPR

If you are an EEA data subject and certain requirements are fulfilled, you have the following data protection rights under GDPR:

• Right of Access. You have the right to access your personal data.
• Right to Erase. You have the right to have us erase your personal data.

If you wish to exercise your "Right of Access" or "Right to Erase", please email us at greg@growbrand.co. Please note that we may ask you to verify your identity before responding to such requests.

Right of Rectification. You have the right to have your personal data rectified / updated if that information is inaccurate or incomplete. Right to Object. You have the right to object to our processing of your personal data carried out for our legitimate reasons and/or for direct marketing, including profiling that is related to such direct marketing.

Right of Restriction. You have the right to request that we restrict the processing of your personal data (i.e., we would need to secure and retain the personal data for your benefit but not otherwise use it). Right to Data Portability. You have the right to be provided with a copy of your personal data in a structured, machine-readable and commonly used format (or have this transferred to a third party). If you wish to exercise one of the above-mentioned rights, please send us your request via email to greg@growbrand.co. Please note that we may ask you to verify your identity before responding to such requests.

Right to Withdraw Consent. You also have the right to withdraw your consent at any time where GROW relied on your consent to process your personal data. If you wish to exercise such right with respect to "interest-based advertising" / "online behavioral advertising" / Tailored Advertising, you can do so through the mechanisms set forth in the "Your Choices: Opt-Out/Right to Withdraw Consent" section above; and if you wish to exercise such right with respect to the advertising and marketing we communicate by email, postal mail, or telephone, please email us at greg@growbrand.co.

You also have the right to complain to a data protection authority about our collection and use of your personal data. We would, however, appreciate the opportunity to address your concerns before you approach a data protection authority, and would welcome you directing an inquiry first to us at greg@growbrand.co.

There are a number of places on our Site where you may click on a link to access another party's website that does not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on our Site, you may be taken to a third-party website that we have no ownership or control. These third-party websites may independently solicit and collect from you and in some instances provide us with information about your activities on those websites. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

We may allow you to connect our Site to a third-party service or offer portions of our Site through a third-party service ("Third Party Features"). If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature, and you should carefully review the third party's privacy policy and terms of use. Some examples of Third Party Features include the following:

Liking, sharing, and logging in

We may embed a pixel or other technology on our Site that allows you to "like" or "share" content on, or log in to your GROW account through, third-party services, including social networks such as Facebook. If you choose to engage with such a third-party service through our Site, we may collect any information you have authorized the third-party service to share with us (such as your user ID, billing information, public profile information, email address, birthday, friends list, and other account and profile data). Likewise, if you choose to engage with such a third-party service through our Site or visit our Site while logged in to that third-party service on your device or through our Site, the third party may receive information about your activities on our Site and be able to associate that information with information the third party already has about you.

Brand pages and chatbots

We may offer our content on social networks such as Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Site on a third-party service (e.g., by using a hashtag associated with GROW in a tweet or post), we may use your reference on or in connection with our Site.

Voice-activated skills

We may offer skills through Alexa and other voice-activated platforms, and use the voice processing and other technologies discussed in connection with automatic data collection and tracking. Any information you provide to us when you engage with our skills is treated in accordance with this Privacy Policy.

Our Site is not intended for children, and we do not sell products for purchase by children. If you are under 18, you may use our Services only with the involvement and permission of a parent or guardian. We do not knowingly collect personal information from children under the age of 13 without the consent of the child's parent or guardian. If you are a parent or guardian and you believe that your child has provided us with personal information, please contact us. (Please see the "Contact Us" section below.) If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove that personal information from our servers.

We may update this Privacy Policy from time to time. The "Last updated" date shows when it last changed. If we make a material change, we will notify you by email or in the app before it takes effect where required by law. Where the law requires your consent, we will ask for it. Otherwise, using the Program after the update takes effect means you accept the updated policy.

If you have any questions about this Privacy Policy or our privacy practices, or if you would like to contact our data protection representative, please feel free to contact us by email to greg@growbrand.co.

If you are a California consumer and have any questions or concerns about our privacy policies or practices, please feel free to email us at greg@growbrand.co.

With respect to the EEA personal data we collect, GROW is the controller responsible for such personal data. As the controller, we determine the purposes for which and the manner in which such personal data are, or are to be, processed with respect to our site.

If you are an EEA data subject and have any questions or concerns about our privacy policies or practices, please feel free to email us at greg@growbrand.co.

If you experience difficulty in accessing any part of our services or this Privacy Policy, please feel free to email us at greg@growbrand.co.