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Privacy Policy

Privacy Notice
Last Updated: May 26,2023 Growie Operations, LLC (“Growie”, “we”, “us” or “our”) is a real estate investment platform. This Privacy Notice explains how we collect, use, disclose, or otherwise process personal information in connection with our website (https://growie.io), any other websites or platforms we own and operate that link to this Privacy Notice, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”). This Privacy Notice is not a contract and does not create any legal rights or obligations. This Privacy Notice does not address our privacy practices relating to Growie employees, contractors, or other personnel.

1. Our Collection of Personal Information We collect personal information in connection with your visits to and use of the Services. This collection includes information that you provide in connection with the Services, information from third parties, and information that is collected automatically, such as through the use of cookies and other technologies. For further information on your choices regarding your information, see the Control Over Your Information section below. Blockchain Participants: Please note that by virtue of the public nature of the blockchain, including the Ethereum Blockchain, the holdings and transactions associated with your cryptocurrency wallet address will be publicly available and accessible to third parties. This includes, but is not limited to, your public sending address (including, but not limited to, cryptographically secure non-fungible tokens, and other blockchain securitized tokens), the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on the blockchain may not be able to be modified or deleted due to the immutable nature of the blockchain. Transactions and addresses may reveal information about the user’s identity and information can potentially be correlated now or in the future by any party who chooses to do so. Please review how privacy and transparency on the blockchain works.

A. Information You Provide to Us Directly We collect and use personal information you provide in the following ways:

  • Contact Information, including first and last name, email address, mailing address, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
  • Account Information, including first and last name, company name, employer, job title, business email address, user ID and password, affiliations, account balances, payment history information, and any other information you provide to us. Note that to engage in investments and related transactions you must connect your crypto wallet, which will provide us with the public blockchain address associated with your crypto wallet, i.e., your “wallet ID” (see the Crypto Wallets section below for more information). We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Service, and for customer support purposes.
  • Investment Information, including account type (e.g., individual, joint), legal investing account name, taxpayer ID number or Social Security Number, account address, ACH information or SWIFT account number, accreditation verification, and additional investment account members.
  • Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
  • Newsletters and Marketing Emails, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices). For more information, please see the Control Over Your Information section below.
  • Information Collected Through the Use of the Service, including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Services (collectively, “User Content”). User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Services. We use the User Content to provide you with the Services.
  • Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.

    B. Personal Information Automatically Collected

    As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:
  • Log Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services. Log data may overlap with the other categories of data below.
  • Analytics data, including the electronic path you take to our services, through our services and when exiting our services, UTM source, as well as your usage and activity on our services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with.
  • Location data, including general geographic location that we or our third-party providers may derive from your IP address, or more precise geolocation with your permission when accessing our online services through a mobile device. We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively, “tracking technologies”) to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding tracking technologies, please see the Control Over Your Information and Third-Party Data Collection and Online Advertising sections below.

    C. Personal Information from Third Parties

    We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual. We may receive the same categories of personal information as described above from the following third parties:
  • Growie Entities: We may receive personal information from other companies and brands owned or controlled by Growie, and other companies owned by or under common ownership as Growie.
  • Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services. For example, if you try to buy tokens from a Growie investor, we may collect information about you from the Growie account-holder.
  • Social Media: When you interact with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
  • Service Providers: Our service providers that perform services solely on our behalf, such as customer service support, marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your investments. We may use this information to administer and facilitate our Services, your investments, and our marketing activities.
  • Background Check and Financial Compliance Service Providers: We may receive personal information about you when you begin the process of investing with Growie from our KYC & AML service provider. We may receive financial regulatory compliance information such as your social security number, date of birth, address, copy of your government-issued identification, residency information (i.e., whether you are a resident of New York), financial information such as income or credit status, and reference information. If you are investing as a business, we may collect information relating to your state of incorporation, directors and officers, financial information, and contact information. We use this information to verify your identity and eligibility to invest with Growie and provide our Services to you. We may also receive information about you from credit reporting agencies to comply with applicable laws and industry standards, such as Know Your Business or Know Your Customer (KYC) and Anti-Money Laundering (AML). For example, we may receive your pass/fail status of a KYC and AML review. We may also receive information from credit reporting agencies to verify your bank accounts and other ownership information. Your interactions with these service providers are governed by the privacy policies of those companies.
  • Crypto Wallets: When you connect your crypto wallet, such as Ethereum, or create one with Growie, we receive information such as your wallet ID, crypto wallet types (including amounts and balances), and any related transaction and technical information associated with your crypto wallet ID, including network information regarding transactions. We use this information to administer your account and provide you with the relevant Services.
  • Public Blockchain Data: Blockchain is a shared, immutable ledger used to record transactions of assets, like Ethereum. The Ethereum Blockchain is a public ledger, meaning anyone in the world can view the transactions recorded on the Ethereum Blockchain. Our Services are designed to pull publicly-recorded transactions from the Blockchain to provide our investors with an easy platform to review information such as Crypto Wallet, the balance associated with the wallet address, and transaction details (including, for example, transaction identifier, Ethereum Blockchain position for the transaction, date and time of the transaction, amount sent or received, fee amount, wallet address of the sender and recipient, and storage size of the transaction). We may combine this information with individual profiles we have based on bon-chain and off-chain information.
  • Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our Services, your orders, and our marketing activities.
  • Other Sources: We may also collect personal information about you that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

    2. Uses of Personal Information
    We may use personal information we collect to:
  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions;
  • Manage our organization and its day-to-day operations;
  • Verify your identity and eligibility to products or Services, when you contact us or access our Services;
  • Communicate with you, including via email, text message, social media and/or telephone calls;
  • For marketing and advertising purposes, including to market to you or offer you through email, phone or text message information and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
  • Administer, improve and personalize our Services, including by recognizing you and remembering their information when they return to our Services;
  • Process payment for our Services;
  • Facilitate customer benefits and services, including customer support;
  • Identify and analyze how individuals use our Services;
  • Conduct research and analytics on our customer and user base and our Services;
  • Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
  • Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
  • Help maintain the safety, security and integrity of our property and Services, technology assets and business;
  • To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • Prevent, investigate, or provide notice of fraud or unlawful or criminal activity;
  • Comply with contractual and legal obligations and requirements;
  • To fulfill any other purpose for which you provide personal information; and
  • For any other lawful purpose, or other purpose that you consent to.
    Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

    3. Our Disclosure of Personal Information
    We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
  • Growie Entities: We may share personal information with other companies owned or controlled by Growie, and other companies owned by or under common ownership as Growie, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
  • Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
  • Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
  • Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, KYC/KYB and background check related services, payment processing services, and administrative services.
  • Other Users: If you participate in our Services, by virtue of the public nature of the blockchain, the holdings and transactions associated with your Crypto Wallet will be publicly available and accessible to other investors, blockchain participants, and other third parties, as well as any other information you choose to provide or make public.
  • Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Please see the Third-Party Data Collection and Online Advertising section.
  • Business Partners: From time to time, we may share personal information with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
    1. in connection with the establishment, exercise, or defense of legal claims;
    2. to comply with laws or to respond to lawful requests and legal process;
    3. to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    4. to detect, suppress, or prevent fraud;
    5. to protect the health and safety of us and others; or
    6. as otherwise required by applicable law.
  • With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

    4. Third-Party Data Collection and Online Advertising
    We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. Please see Online Ads of the Control Over Your Information section below, to learn how you can opt-out of interest-based advertising. We may engage in the following:
  • Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
  • Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, “How Google uses data when you use our partners’ sites or apps”. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, or by visiting NAI’s online resources.
    For more information about these practices and your choices regarding tracking technologies, please see Online Ads of the Control Over Your Information section below.

    5. Control Over Your Information
    You may control your information in the following ways:
  • Access to Your Device Information. You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications.
  • Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
  • Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.
  • SMS Text Messaging. You may opt-out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from SMS texts from Growie directly relating to your use of the Services, such as for account login (e.g., we may send you a security verification code). To unsubscribe from promotional SMS texts, you can reply STOP to any one of our promotional text messages. For more information, see our Terms of Service.
  • Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at contact@growie.io. We may not be able to modify or delete your information in all circumstances.
  • Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).
    Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

    6. Children’s Personal Information
    Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 18. If an individual is under the age of 18, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

    7. Links to Third-Party Websites or Services
    Our Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

    8. Updates to This Privacy Notice
    We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

    9. Contact Us
    If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to contact@growie.io.