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Privacy Policy

Privacy and Cookie Policy

Growd respects your privacy and is committed to protecting it. This Privacy Policy describes the policies and procedures that govern the collection, use and disclosure of your personal information when you use Growd. We will not use or share your confidential information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect from other sources. Information that you submit to Growd for the purposes of listing learning activities may be publicly available and disclosed. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in Growd’s Terms of Service.

The Growd Service is operated by Growd Global Ltd., trading as Growd, also referred to as “We” and “Us”.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies only to your relationship with “the Covered Parties” as defined in the Growd Terms of Service. It does not apply to the interactions that you have with any other individual, entity, investor or other group on or through Growd.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use Growd, and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Privacy Policy applies to information we collect:

  • On Growd;

  • In e-mail, text and other electronic messages between you and Growd, on the site or otherwise; and

  • When you interact with our links and applications on third-party websites and services if they include a link to this Privacy Policy.

It does not apply to information collected by:

  • Us offline or through any other means; or

  • Any third party (including our partners, affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on Growd.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use Growd. By accessing or using Growd, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of Growd after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

GENERAL DATA PROTECTION REGULATION (GDPR)

The GDPR is an EU Regulation to improve the protection of the personal data of EU citizens and increase the obligations of organisations who collect or process personal data. These new regulations take effect on the 25th of May 2018. The regulations greatly enhance the data privacy and security of our customers and extend to them exercisable rights enabling greater control over one’s personally identifiable information.

The full specification of the GDPR rights and regulations can be found (here).

Growd functions as both a controller and processor of our customers’ personally identifiable information (PII). Additionally, we employ a number of sub-processors to which we transmit data for storage or processing beyond feature sets under our immediate control.

As a controller of data, we store PII such as customer names, IP addresses, and email addresses. We use databases through GDPR compliant service providers (AWS, Heroku, mLab) to store sensitive customer data.

Growd is also a processor of customer data. We use customer data to recommend different learning experiences for users and use our machine learning algorithms to predict user behaviour in order to provide personalised content.

DEFINITIONS

This Privacy Policy is a part of the Terms of Service for Growd. The terms “Covered Parties,” “Growd,” and “Growd Content,” as well as all other capitalized terms not otherwise defined in the Privacy Policy have the same meaning set forth in the Growd Terms of Service.

WHAT IS “PERSONAL DATA”?

“Personal data” is any data that (1) is recorded in any form, (2) is about or pertains to a specific individual and (3) can be linked to that individual. For example, and without limitation, your first and last names, address, email address, telephone number, and other contact information are “personal data.” Personal data does not include website data, aggregated data, uploaded documents, or profile information about a commercial business or not-for-profit organization.

WHAT KIND OF PERSONAL DATA IS COLLECTED?

We collect and store information that you provide to us. This includes information you choose to provide when:

  • You sign up for Growd services

  • You make bookings via Growd

  • You contact Us (for example, when you send us emails)

  • You review a learning experience provider on Growd

  • You participate/write content in the Growd community

INTERACTION AND TRACKING DATA

We record information about how you use Growd services, for example screens you have viewed on the app, content you have shared in the Growd community feature or activities you have saved.

DATA PROVIDED BY PROVIDERS

If you book an activity through Growd, and then request a refund, the provider who operates the activity may inform us about that.

HOW WE USE INFORMATION WE COLLECT FROM YOU

We use the information you provide us, or that we record about you, to:

  • Administer accounts you sign up for

  • Allow you to book activities

  • Provide you with information about services you have requested, for example, booking confirmation emails

  • To send you important administrative emails, for example, if we make significant changes to our terms

  • Respond to emails that you send us

  • Respond to content you have shared in the Growd community feature

  • Send you marketing messages if you have opted-in to receive them

  • Provide you with lists of relevant activities when you are using the app

  • Improve our products and services by analysing interaction and user data

  • Provide aggregated data to our partners

  • Optimise and improve our marketing campaigns

  • Respond to requests by government or law enforcement agencies, and meet legal regulatory and compliance obligation, to the extent we are required to by the law.

We collect personal data at different stages of your use of Growd.

  • When you visit Growd: If you visit Growd or use an interface which interacts with Growd, we collect your IP address, the location of your Internet Service Provider, the type and version of Internet browser that you are using, and the website from which you came. We also collect information regarding your site usage, such as the time spent on a page and the number of pages you viewed.

  • When you interact with Growd: We also collect personal data that you provide when you interact with Growd such as, for example, by sending a message or uploading documents, or when exchanging correspondence with us or our Growd community feature.

  • When you use submit User Content:

    • If you submit content about yourself, such as your contact information, picture, number of children, children’s ages and information. While your username name will be public, no other information will be publicly disclosed.

    • If you contribute in the Growd parent community, while your personal information will be confidential, your username and the content of your contribution will be publicly disclosed.

If you provide any information about or personal data of a third party (such as a person’s name or photograph), you are representing to the Covered Parties that you have all necessary authority and/or have obtained all necessary consents from such individual to enable the Covered Parties to collect, use and disclose his or her personal data as set forth in this Privacy Policy. If we receive a written complaint or direction from the person, we will take down his or her information and notify you that we have done so.

WITH WHOM MAY THE COVERED PARTIES SHARE PERSONAL DATA?

Under certain business or legal conditions, Growd may have to disclose your personal data to others as follows:

  • Within the Growd Family: Growd may now or in the future have a parent, subsidiary or related company or companies within the Growd family of companies. Growd has the right to share all personal data with all such affiliated companies.

  • Learning Experience Providers: Growd is working with vetted learning experience providers who provide co-curricular learning activities. For these providers to perform this function, they will have access to some personal information (First name of user, first name of children, ages of children and gender of children). These providers have agreed not to use the personal data for any other purpose other than providing the required services.

  • Legally Required Disclosure: Under certain circumstances, disclosure of your personal data may be required by law. Growd may disclose your personal data (1) if, in its own best judgment, it is required to do so in order to comply with a facially valid judicial or governmental subpoena, warrant, or other order, or (2) to a government institution that has asserted its lawful authority to obtain the information, or (3) in connection with the exercise or defense of its rights.

  • Change of Ownership: If ownership of Growd changes as a result of a merger, acquisition, or transfer to another company, your personal data may be transferred to the successor entity. If such transfer takes place, you will be notified of any material changes to the Privacy Policy and provided with the ability to opt-out of the transfer of your personal data to the successor entity.

  • With Partners: Growd may share aggregated information provided by you when you submit User Content. You may opt-out by emailing help@growd.org.

CAN I ACCESS OR CHANGE MY PERSONAL DATA?

All users of Growd can access the personal data that Growd holds about them and can see it listed in their profiles, by going to your profile page on the app with the login credentials provided when the data was submitted through the Growd app. They can correct, amend, or delete this data at their convenience.

CAN I HAVE MY PERSONAL DATA DELETED?

You can contact help@growd.org to delete any personal data that is recorded in the profile that you create for yourself as a customer or as a learning experience provider. You may delete your Growd account from within the Growd mobile app.

Retention of Your Data

We are committed to only keeping personal data while it is being used. Our current policies for disposing of personal data are:

  • We will delete your Growd app user account data if you have not used Growd’s products for 2 years.
  • We will anonymise all interaction data that is older than 12 months.

If you delete your account we will delete all your account data and anonymise tracking data connected to your account.

WHAT IS AGGREGATED DATA, AND HOW IS IT USED?

Data aggregation is a process in which information is gathered and expressed in a summary form for purposes such as statistical analysis, in order to obtain information about a particular group based on specific variables. Data used for aggregation purposes are collected in a form that removes all identifiers, and may be combined with other data for which all identifiers have also been removed. Aggregated data may be packaged and licensed to third parties such as governments, economic development agencies and financial institutions. Examples of aggregated data may include:

  • Data about the trends in booking activities. These trends may include, age groups differences preferring certain activities, mode of payments used, repeat bookings in certain types of activities, time of day,week or month bookings are made and so on.

  • Data about general trends in contributions made in the Growd parent community. These may include topics, frequently talked about by parents, time of day most questions and responses are contributed and children’s age groups whose parents require the most assistance.

COOKIES AND ACTION TAGS

  • Cookies Growd uses ‘cookies.’ Cookies and similar technologies are used to store pieces of information on your computer or mobile device when you visit a website or use an app. Cookies are used to make site navigation easier, and can help recognize a returning visitor. We also use cookies to improve Growd’s services.

The cookies we set enable Google Analytics software to collect information about how you use Growd. We do this to help make sure the site is meeting the needs of its users and to help us make improvements. Google Analytics stores information about:

    • the pages you visit on Growd

    • the amount of time you spend on each Growd page

    • where you came from to get to the site

    • the content you select while you’re visiting the site

  • Growd’s cookies do not generate any personal data, do not read personal data from your computer, and are not tied to any personal data. Most browsers and mobile devices automatically accept cookies.

  • Action Tags Growd uses action tags. An action tag is a small piece of code that is placed on a webpage or a mobile platform in order to track the pages viewed or the messages opened, the date and time when someone visited our website or mobile app, the website or mobile app from which the visitor came, the type of browser used, and the domain name and address of the user’s Internet Service Provider. Action tags allow us to better understand how users and visitors use our site or browse through our pages, so that we can improve access to and navigation through the site, add or modify pages, according to our user’s patterns. Action tags cannot be removed or deleted by our users, because they are part of the programming of a webpage or a mobile app.

  • Log Files Log file information is automatically reported by your browser or mobile device each time you access a web page or mobile app. When you use Growd, our servers automatically record certain information that your web browser or mobile device sends out whenever you visit any website or mobile app.

  • Web Beacons When you use Growd, we may employ web beacons, which are used to track the online usage patterns of Users anonymously. No personally identifiable information from your account is collected using these beacons. In addition, we may also use web beacons in HTML-based emails sent to Users to track which emails are opened by recipients.

  • Do Not Track Signals Growd does not track or use Do Not Track signals.

You may refuse to accept cookies by activating the setting on your browser or your mobile device which allows you to refuse the setting of cookies. If you select this setting you may be unable to access certain parts of the Growd Service. Unless you have adjusted your browser or mobile device setting so that it will refuse cookies, Our system will issue cookies when you log on to the Growd Service. You can learn more about cookies by visiting: www.allaboutcookies.org or www.networkadvertising.org.

WHAT SECURITY MEASURES ARE IN PLACE TO PROTECT MY PERSONAL DATA?

Growd uses physical, technical, and administrative procedures in order to safeguard and protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, while we do our best to implement reasonable security measures, we do not guarantee that our safeguards will always work.

Growd uses industry-standard technological means to protect your personal data while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. However, please remember that no security system on the Internet is perfect.

WHAT ABOUT UPLOADED DOCUMENTS?

Documents that are uploaded to Growd for sharing are stored at a third party data-storage service. All uploads and downloads are transmitted through the web between users and the data storage service using the same encryption techniques as those that are used with personal data. However, uploaded documents are neither stored redundantly, nor backed up. Therefore, we recommend that users keep back-up copies of their documents if they upload them to Growd.

WHEN WILL GROWD OR ANYONE ELSE CONTACT ME?

Growd will communicate with you in response to your inquiries regarding content partnerships, website support, business development, or existing content on Growd. We will contact you by phone or by email, according to your preference. Growd will always send you a confirmation email of the activities booked via Growd and may also send you an email in order to notify you of new services or features, or updates to the Privacy Policy or Terms of Service. If you proactively opt-in to receive periodic news or digests from the site, Growd will also send you such news or digest emails until such time as you proactively opt-out.

Growd will send you service-related emails if it becomes necessary to do so. Growd may also send you an email in order to notify you of new services or features, or updates to our Privacy Policy, Terms of Service, or other agreement(s) that you have with Growd.

LINKS TO OTHER WEBSITES

Growd may provide links to other websites. We are not responsible for the privacy practices or content of these sites. In order to safeguard your privacy, please review the privacy policies of any sites that you may visit before providing any personal data to these third party sites.

LIMITATION OF LIABILITY

The Covered Parties exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. The Covered Parties will not be liable for unauthorized disclosure of personal data that occurs through no fault of the Covered Parties including, but not limited to, errors in transmission, access to your account by anyone uses your user ID and password, your failure to comply with your security obligations, and the unauthorized acts of the Covered Parties’ employees.

CHOICE

If at any time Growd wishes to disclose, or use your personal data in a way, or for a purpose other than as described in this Privacy Policy, Growd will give you the opportunity to choose (opt out) whether your personal data (1) may be disclosed to a third party and (2) may be used for a purpose other than the purposes that are set forth in this Privacy Policy.

CHANGES TO THE PRIVACY POLICY

From time to time, this Privacy Policy may be updated in order to reflect changes in practices. Whenever such changes are made, an updated Privacy Policy will be posted on Growd and users who have shared their contact information may be emailed. All changes will apply to the personal data that are already collected, and to personal data that are collected after the effective date of the revised Privacy Policy, and will become effective when posted. You will have the right to delete your profile at any time.

CONTACTING GROWD

Growd is operated by Growd Global Ltd. Our mailing address is Rhapta Terraces – Rhapta Road, Westlands. P.O Box 756 – 00515 Nairobi, Kenya

If you have any questions about this Privacy Policy, or believe that its terms have not been complied with, please email us at: help@growd.org

Effective Date: October 8th 2019.