TABLE OF CONTENTS
- 1. The Scope
- 2. What Personal Data Do We Have on You
- 3. No Requirement to Disclose Personal Information
- 4. What Personal Data We Collect
- 5. Legal Basis and Reasons for Processing of Personal Data
- 6. Transfer of Personal Data to Third Party
- 7. Cookies and Services from Third Parties
- 8. Retention of Personal Data
- 9. International Transfers
- 10. Security of Personal Data
- 11. Hyperlinks to Third Party Websites
- 12. Modifications to This Policy
- 13. Your Rights
Privacy Policy
We (referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the website Growntester (the "Website").
We want you to be able to make informed choices about the use and processing of your Personal Data. We use different methods and procedures to provide you with relevant information, and if we believe you require specific details, we'll provide these at the appropriate time. We're happy to answer any questions you may have regarding any limitations imposed by law.
1. The Scope
1.1 This policy describes the type of Personal Data the Company collects from natural individuals, and how it processes it, shares it with third parties, secures it, and so on.
1.2 This Policy relates to information connected to an identified or identifiable natural person. An identifiable natural person is someone who can be identified either directly or through a combination of additional information we hold or can access.
1.3 The Policy defines "processing" as any activity involving the use or collection of Personal Data. This includes managing, structuring, and storing Personal Data.
1.4 Our services are intended for use by general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from anyone younger than 18 years old, nor do we knowingly allow such persons to use our services. If we learn that we have collected information about a child, we will erase it as quickly as possible.
2. What Personal Data Do We Have on You
2.1 We collect Personal Data when you access our service and channels, or visit our website. In certain instances, we may also request your Personal Data.
2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving your information from our third-party partners.
3. No Requirement to Disclose Personal Information
3.1 You are not obliged to provide Us with any Personal Data. In certain circumstances, however, you may need to supply Us with Personal Data. Without it, We may be unable to offer the Services or allow you to access the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log, along with data about your traffic, including:
- IP address
- Date of access and time of access
- Language you used
- Software crash logs
- Type of browser used
- Information regarding the device that you utilised
4.2 The information collected is not private information and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect with a third party's online trading platform through Us.
4.4 Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
5.1 The company processes your personal data for the purposes outlined in this section, in accordance with the applicable legal basis.
5.2 The Company cannot use your Personal Data without a legal basis. The legal grounds on which the Company may process your Personal Data are as follows:
- You have given your consent for your personal data to be processed for one or more reasons. This applies when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may need to process data to meet their legitimate interests, for instance to improve Our Services or to defend legal claims.
- Processing must meet an obligation of law.
5.3 Contact us via email for more details regarding the processing necessary to safeguard our legitimate interests.
5.4 Below is a list of reasons and legal grounds we may rely on when using the information you provide us with:
Scope
Legal Basis
1. To share your personal information with third parties at your request, to give you access to digital trading.
If you ask us to, we may request personal data from you in order to forward it to third-party companies.
You have given your consent for your Personal Data to be processed for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is necessary to help us answer any questions you may have regarding the Services.
Processing is necessary for the legitimate interests of the Company or the interests of a third party.
3. To comply with any legal, administrative or judicial obligation, Personal Data is processed to meet applicable legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To Improve Our Services
We may use Personal Data to improve Our Services. This includes, among other things, any crash or malfunction reports we collect in relation to the Services.
The legitimate interests of the Company or the interests of a third party need to be pursued.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the legitimate interests of the Company or the interests of a third party.
6. To carry out and manage actions in line with the requirements of Our Services
Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.
To process the legitimate interests of the Company or the interests of a third party.
7. To carry out analysis, such as statistical analysis
To make decisions on various matters, we use a range of analytical techniques (including statistical methods).
To process the legitimate interests of the Company or the interests of a third party.
8. To safeguard our assets, rights and interests, as well as those of third parties
Personal Data may be processed by us to safeguard our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements, and any conditions, terms or policies.
To process the legitimate interests of the Company or the interests of a third party.
6. Transfer of Personal Data to Third Party
6.1 The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and analysis of user experience.
6.2 You can also ask us to provide your specific Personal Data to third-party trading platforms. In these instances, we will share the Personal Data you provide to Us with trading platforms of third parties. The use of your Personal Data will then be subject to their privacy policies. Your Personal Data could be shared with multiple trading platforms.
6.3 The Company may share Personal Data with related entities or business partners. This provides the Company with the resources needed to enhance and improve the products and services it offers its customers.
6.4 Where necessary to safeguard the rights of third parties or assets, the Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.
6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, should such a transaction take place (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of any merger, restructuring, consolidation or bankruptcy involving the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may use third-party services, such as advertisers on our website or analytics providers. These companies may also use cookies or similar technology.
7.2 Cookies are tiny text files placed on your device every time you visit or access the website. They're used to gather information about your preferences and browsing habits to improve the user experience, remember your preferences and tailor the products and services you might enjoy. Cookies are also used for statistics and analytics.
7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and last only for a short time until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They help the Website recognise you as a returning user and allow you to come back to the website easily.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to let you access the features you've requested and to navigate our website. They're used to provide the information, products and services you've asked us for.
They're required for your device to download and stream data, letting you navigate around the website, use its features, and return to pages you've previously visited.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm that you're logged in to the site. They're deleted once you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognise you each time you visit our site and also to save your preferences.
Additional Information
They remain valid until the expiry date and are saved even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow Us to carry out analysis on our website.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable or identified natural person. Some are removed when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, you'll need to change your browser's settings. Below are links to help you with this for a few of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, please note that if this happens, some or all of the Website's functions and features might not work as you expect.
Online Tracking Notice: This service does not currently support do-not-track signals.
8. Retention of Personal Data
8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing Personal Data, as described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.
8.2 We'll share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue sharing your data for a further 12 months.
8.3 We regularly review the Personal Data we hold to make sure it's no longer needed.
9. International Transfers
9.1 Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country or to international organisations). The Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data users are able to assert their rights and access effective legal recourse.
These protections and safeguards are available to everyone residing in the EEA (European Economic Area):
- Transfer to a third country or international organisation which the EU Commission has determined provides adequate protection of Personal Data transferred to it, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a)
- The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.
9.3 The Company can provide details about the security measures it uses to safeguard your Personal Data when it is transferred to third-party countries or international organisations. Send an email to: support@growntester.best
10. Security of Personal Data
10.1 We have implemented appropriate organisational and technical measures to safeguard Personal Data. This includes protection against accidental or unlawful destruction, loss or modification of Personal Data.
10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. Nor can we be held accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to errors in transmission, unauthorised access by a third party, or any other cause beyond our control.
10.3 Where we are subject to legal obligations or other requirements beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. In these situations, we have no control over the security measures applied to your Personal Data by those third parties.
10.4 No transmission of Personal Data over the internet can be guaranteed as completely secure. The Company cannot ensure the security of any Personal Data you send to Us over the internet.
11. Hyperlinks to Third Party Websites
11.1 The website may contain links to third-party sites and applications. These applications and websites are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.
11.2 Before accessing or using any third-party websites or apps, We recommend that you read their privacy policies. We also suggest that you carefully consider before providing any Personal Data to them.
12. Modifications to This Policy
12.1 This Policy may change at any time. If we make changes, We will notify you by posting the updated Policy on our website.
12.2 In addition, when we make significant changes to this Policy, we will attempt to inform you using the methods we believe to be appropriate and will publish an announcement on our website.
12.3 Unless otherwise stated, any amendments will take effect once the revised Policy has been published.
13. Your Rights
13.1 You are entitled to ask us to verify the accuracy of any Personal Data being collected about you, to correct any errors, and to delete any Personal Data We are not required to keep. You may also restrict the scope of the types of processing applied to your personal information.
13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. You may request to exercise these rights by writing an email to the address below.
13.3 Access rights The Company can verify whether Personal Data relating to you is being processed. If it is, you have the right to access your Personal Data. The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. Data will be provided electronically if requested. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to another person's rights and freedoms, the Company can refuse to comply with the request or limit its ability to fulfil it.
13.4 Right to rectification The Company is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.
13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) You withdraw consent and there is no other legal basis for processing; (c) You object, on grounds relating to your particular situation, to the processing of Personal Data about yourself based on legitimate interests pursued by Us or by a third party; (e) Personal Data have been unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfill an obligation imposed by European Union law or Member State law; or (b) to establish, exercise, or defend legal claims.
13.6 Processing restrictions If you are concerned about the accuracy of your Personal Data, you can ask the Company to limit the processing of your Personal Data. If you ask that Personal Data be restricted, Personal Data may only be kept if you give consent, or in order to establish, exercise or defend legal rights, or to protect the rights of another natural person, or for reasons of significant public interest within the European Union or a Member State.
13.7 Right to data portability If processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the legal right to review the Personal Data you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where this is technically feasible. Your rights under the right to erasure remain unaffected by the exercise of your right to data portability. The right to data portability does not interfere with the rights or freedoms of others.
13.8 Right to challenge You may object at any time to any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This is not limited to profiling based solely on these legitimate interests. Where we can establish compelling legitimate grounds for processing Personal Data, we will continue to do so unless you can demonstrate that your rights, freedoms, or interests outweigh those grounds, or that the processing relates to the exercise, establishment, or defense of legal rights. Regarding direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
13.9 Right to refuse consent You may withdraw your consent for Us to process Personal Data about you at any time. This will not affect the legality or lawfulness of any processing carried out based on your consent prior to its withdrawal. You are entitled to lodge a complaint with the authority that supervises you. You may lodge an appeal with a supervisory authority established by a member state to safeguard the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and its Member States may limit your rights in relation to Personal Data concerning you, as detailed in this section 13.
13.10 We will provide the information you've requested, in line with your rights under section 13 of this agreement, within one month of receiving your request. This time frame may be extended by up to two months where needed, depending on the nature and number of requests. If an extension is required, we will notify you within one month of receiving your request, along with the reasons for the delay.
13.11 Provided it is not contrary to the provisions of section 13 of the law, information you request under your rights in section 13 will be provided free of charge. If a request is unfounded or excessive, particularly where it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act on the request.
13.12 If we have doubts about the identity of the person who submitted your request, we may ask that person to provide reasonable proof of identification.
This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.
Growntester 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@growntester.best