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Privacy and Data Protection Policy
The Privacy and Data Protection Policy establishes the terms used by Growappy to handle the personal data of its users and the rights they can leverage, according to Regulation (EU) 2016/679 of the European Parliamant and to the Council of the General Data Protection Regulation (GDPR), as well as any applicable national legislation (Portugal) in the matter of privacy and data protection.
What kind of data do we collect?
To supply this service we need to process some information about you. The type of information we collect depends on the way how you use Growappy.
• Information and content you supply
We collect the content, communications and other information that you supply when you're using Growappy. This can include information present on or about the content that you share with Growappy, such as file metadata, device location and other details, having the purpose to imrpove the user experience in features such as school searching.
• Networks and connections
We collect information about schools that you're connected to, whether as na administrator, employee or a tutor, as well as how you interact with a school.
We collect information about the way how you use Growappy, such as the content that you visit or interact with, the features that you use, the actions you perform, as well as when, for how long and how often you use certain features. For example, we log when you're using Growappy as well as when you last used it. We also collect information about how you use each of the features of Growappy.
• Information about transactions conducted in Growappy
If you have a subscription in Growappy, we collect information about the purchase or transaction when enabling, activating or renewing subscriptions. This includes history about payments performed towards Growappy but it does not include details of your payment methods, such as credit card numbers or other details of a credit card. Growappy also collects details on invoicing and contacts towards Growappy.
• What device information do we collect?
As mentioned below, we collect information of and about the devices that interact with Growappy and combine that information across multiple devices that you use for Growappy. For example, we leverage the way how you use Growappy on your mobile device to tailor your user experience and content presented to you, including advertisement, or adapt the content and features you use when resorting a separate device such as a tablet or a PC.
The information we obtain from those devices include:
• Device attributes
Aspects such as the operating system, software and hardware version, battery levels, signal strenght, available storage space, browser type, available application names or ID, as well as other plug-ins.
• Device signals
Information about mobile cellular towers and WiFi network availability in proximities.
• Device configuration data
Information that allows us to understand if the device is granting access to GPS (geolocation), camera or photo/video gallery.
• Networks and connections
Information such as your mobile or internet service provider (ISP), language or locale, time zone, phone number, IP address and the bandwidth of your connection.
• Cookie data
How do we use your personal data?
We only use personal data that we collect from you (subject to your choices in Growappy) for specific purposes:
• To promote protection, integrity and safety
We use the information we have to verify accounts and actions, fight against misconduit, detect and prevent spam or other bad experiences, to maintain the integrity of our service as well as to promote protection and satety. For example, we use the data collected to investigate on suspitious activities or disrespect to our terms or policies.
• To offer you our service
This usage of personal data also allows us to offer you our service, manage your registration, your account, your access and usage of our website and applications, to be able to publish your reviews as well as to manage and facilitate the queries you conducted within Growappy.
• To communicate with you
We use the information we have to send you marketing communications, to reach out to you regarding our service and to inform you about our policies and terms. We will also use your contact details to reply to you when you engage a contact with Growappy.
We only use your personal data in cases allowed by law. We may also use your personal data under the following circumstances:
• Whenever we have to execute the contract which we will celebrate or have already celebrated with you
• Every time it's necessary for legal reasons for Growappy or a third party entity, where the interests and fundamental rights of the user isn't superseeded by those legal reasons
• With your consent
• Every time Growappy is required to complay to legal or regulatory obligence
With who do we share your personal data?
Growappy may share information with third party entities, including other companies of the group under the following categories of entities. For example, if we sell or abdicate from our company, or share any participation in the company, if your personal data is associated in the participation that is sold or abdicated from, or in the event of merge with another company, we will proceed with sharing this data with the new company composition or partner of merge or sale.
Separately, if we're required by law, we will share personal data to protect our users, the Growappy service as we all as our company, our rights and entitlements.
If you decide to register in Growappy, some information of your profile may become publicly visible and identifyable from your online alias. You will have the possibility to preview your profile as it is presented to the public. However, Growappy will not share your e-mail address or any forms of contact or financial/tax data with any other user or expose it publicly.
We can also share your information if we see fit, under our exclusive criteria, that the requested share is necessary to:
• To comply with summons, court decisions or other legal processes with executive force; to establish or execute our legal rights; in defence against court orders; or on any other form demanded by law. In these cases, we reserve the right to leverage or renounce to any legal rights or juridic objections that are available to us.
• To investigate, prevent or take measures against illegal activities or suspects of illegal activities; to protect and defend the rights, property or safety of Growappy, of our customers or other people; and in conformity with our User Terms and other agreements.
• In the context of a commercial transaction, such as alienation, merge, consolidation or sale of actives, as well as in the event of bankrupcy.
Except for the cases previously mentioned, you will be duely informed of your personal data is being requested for sharing with a third party entity, where you will have the opportunity to choose if you accept or not that we share the involved information.
We may also share aggregated or anonymized information with third parties, including advertisers and investors. For example, we can share to our advertisers the number of visitors that our website receives and what are the most popular or highest ranked schools. The mentioned information does not include any personal data and the share of information has only the purpose of developing services and content that we hope to be in your best interest.
Share with external partners
We work with external partners that help us provide and improve our service or which use the Growappy APIs to expand their business. We do not sell your personal data nor will we ever. We also impose rigorous restrictions on how our partners can use and publish the data we provide them. Here's the types of partners that we share information with:
We provide reports to advertisers about the profiles of people that watch their ads and how they perform, but we do not share information that individually identifies a person (such as name, e-mail address or other information that could be used to contact a person), unless a person grants us explicit permission to do so. For example, we provide advertisers generic demographic information which is related to interests (like an ad that was watched by a woman of age between 25 and 34 living in Lisbon), in order to help advertisers understand their audience better.
We provide information and content to suppliers that support our business, such as suppliers of technical infrastructure to run Growappy on, suppliers to analyze how Growappy is used, suppliers to provide customer support, to facilitate payments, conduct inquiries, among others.
What is our juridical basis for treating data?
We collect, use and share the data in the forms described above:
• As necessary to comply with our service User Terms
• In a way that is consistent with your consent, which you can revoke at any moment in the Growappy profile settings
• As needed to comply with our legal obligations
• In the defense of your vital interests or the vital interests of third parties
• As necessary according to the public interest
• As necessary to our legitimate interests (or of third parties), including our interest to provide an innovative, personalized, secure and profitable service to our users and partners, except if your interests or freedom and fundamental rights prevail in a way that requires protecting personal data
How can you leverage your rights under the domain of the GDPR?
Under the domain of the General Data Protection Regulation, you have the right to access, correct, transfer and erase your personal data. You also have the right to opose and restrain a certain treatment of your data. This includes:
• The right to oppose to our treatment of your data for purposes of direct marketing, which you can leverage by choosing the option of "cancel subscription" in such marketing communications.
• The right to oppose to our treatment of your data while we're conducting actions of public interest or to address our legitimate interests or legitimate interests of third parties.
• Keeping data, deactivating and eliminating accounts in Growappy
We keep personal data until it's no longer necessary for us to provide our service or until your account is eliminated, whatever happens first. This is determined case by case and depends on factors such as the nature of data, the reason why the data was collected or treated, as well as operational or legal needs to retain the data. Know more about the elimination of content that you shared as well as cookie data obtained from social plugins in our Cookies Policy.
By eliminating your account in Growappy we will delete the content that you published and you will not be able to recover this information later. The information that other people share about you are not part of your account and will not be eliminated. If you do not want to delete your account but desire to stop using the Growappy services, you can request to deactivate your account.
How do we respond to legal requests or prevent damage?
We access information, preserve it and share it with the regulatory enitities, authorities or third parties:
• In response to legal requests, should we consider, in good faith, that the law demands it so. We can also respond to legal requests should we consider, in good faith, that such response is mandatory by law in that jurisdiction, which affects users in such jurisdiction and in coherence with reknown international norms.
• When we consider, in good faith, that it's necessary to detect, prevent and resolve situation of fraud, unauthorized usage of products or services, breaking of our terms or policies, as well as any other illegal or harmful activities; to protect Growappy (including our rights, property or products and services), to protect you and other people, including as part of investigations or regulatory inquiries; or to prevent an imminent situation of death or physical harm. For example, if it's relevant, we provide and receive information to/from external partners concerning the reliability of your account, in order to prevent situations of fraud, abuse and other harmful activities inside or outside our offering of products and services.
The information we obtain about you (including data of financial transactions related to purchases conducted in Growappy) may be accessed and retained for a larger period of time if that information is subject of legal requests or obligations, of government investigations or of investigations concerning possible breaches of our terms and policies, which aim to cause damage. We also keep information on deactivated accounts due to User Terms breaches for a minimum period of one year in order to avoid repeated abuse or infraction of our terms.
How will we notify you regarding changes to this policy?
We will notify you before performing changes to this policy and we'll grant you the opportunity to view the modified policy before opting to continue using Growappy.
How can you contact Growappy?
You can learn more about how Growappy privacy works. If you have questions about this policy, you can contact us via the e-mail address:
Date of last revision: 20th February 2019
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