Growntester

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

Last updated: 06.09.2026

We (also 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 how your Personal Data is used and processed. We use different methods and procedures to provide you with relevant information, and where we believe specific details are needed, we'll share them with you at the appropriate time. We're happy to answer any questions you may have regarding any limitations imposed by law.

By using our Website, you confirm that you have read and agree to this Privacy Policy. For questions, contact: support@growntester.best

1. The Scope

1.1 This policy outlines the types of Personal Data the Company collects on 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 have, or are able to access.

1.3 The Policy defines "processing" as any activity that involves the use or collection of Personal Data. This includes the management, structuring, and storage of Personal Data.

1.4 Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly allow such persons to use our services. If we become aware of any information relating to children, we will delete it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you access the service and channels, or visit our website. In certain instances, we may also request your Personal Data directly.

2.2 In other instances, we gather 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 choose not to supply Us with any Personal Data. This could prevent Us from offering the Services or prevent users from accessing the website.

4. What Personal Data We Collect

4.1 This includes information about your online activity log, along with traffic data such as:

  • 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 you collect is not personal 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 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 Without a legal basis, the Company cannot use Personal Data concerning you. The legal grounds on which the Company is able to process Personal Data regarding you are as follows:

  • You have given your consent to the processing of your Personal Data for one or more reasons. This applies where 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 carry out processing to meet their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
  • Processing must meet an obligation of law.

5.3 Contact us via email for further details regarding the processing necessary to safeguard our legitimate interests.

5.4 Below is a list of reasons and legal grounds on which we may use the information you provide us with:

Scope

Legal Basis

1. To provide your personal information to third parties at your request, in order to gain access to digital trading.
If you ask us to, we may request Personal Data from you to forward it to third-party companies.

You have provided 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 address any questions you may have regarding the Services.

To process the legitimate interests of the Company or the interests of a third party.

3. To comply with any legal, administrative, judicial or regulatory obligation, Personal Data is processed to meet the 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.

Processing is necessary for the legitimate interests of the Company or the interests of a third party.

5. To stop fraud and misuse of Our Services.

To process 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 conduct analysis, such as statistical analysis
To make decisions on various issues, we use a range of analytical techniques (including statistical methods).

Processing is necessary for 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
We may process Personal Data to safeguard our rights, interests and assets, or those of a third party, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.

Processing is necessary for 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 user experience analysis.

6.2 You can also ask us to provide your specific Personal Data to third-party trading platforms. In these instances, we will provide the Personal Data you give us to those third-party trading platforms. The use of your Personal Data will then be subject to their privacy policies. Your Personal Data may 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 protect assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.

6.5 We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company in the group, in connection with such a transaction (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 advertising providers or analytics companies. These companies may also use cookies or other similar technologies.

7.2 Cookies are small 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, keep track of your preferences and tailor the products and services you might enjoy. Cookies are also used for statistics and analytics.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only for a short time, expiring once 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 visitor and allow users to return to the site.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are necessary for you to access the features you've requested and to navigate our website. They are used to provide the information, products and services you've asked us for.
They enable your device to download and stream data, allowing you to navigate 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 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 and settings.

Additional Information

They remain valid until the expiry date and stay saved even after the browser is closed.

The type of cookie

Cookies for performance

Scope

Cookies are used to gather 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 adjust your browser's settings. Below are links to help you through the process for some of the most popular browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please be aware 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 currently does not 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 that 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 to this, we will continue sharing your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to check whether it's still needed.

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted 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 anyone 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 information about the security measures it uses to protect your Personal Data when it is transferred to third-party countries or international organisations. To request this information, email: support@growntester.best

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to safeguard Personal Data. This includes preventing 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're subject to legal obligations or other requirements beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. In these situations, we have no control over how securely third parties handle your Personal Data.

10.4 No data transmission over the internet can be guaranteed completely secure. The Company cannot ensure the security of Personal Data you transmit to Us via 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 If you visit any third-party websites or apps, we recommend reading their privacy policies before deciding to access or use them. We also suggest you consider carefully 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, if we make significant changes to this Policy, we will attempt to notify you using the methods we consider appropriate and will publish an announcement on our website.

12.3 Unless otherwise specified, any amendments will take effect once the revised Policy has been published.

13. Your Rights

13.1 You are entitled to request that we verify the accuracy of any Personal Data being collected about you, correct any mistakes, and delete any Personal Data not required by Us. 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 are available to you with respect 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. Where this is the case, you are able 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. The data will be made available electronically if you request it. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to the rights and freedoms of another party, 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 for processing.

13.5 Right to Erasure The following reasons are applicable: (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 legal basis for processing; (c) You object, at any time and on grounds relating to your particular situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are 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 comply with a legal obligation under European Union law or the law of a Member State; or (b) to establish, exercise or defend legal claims.

13.6 Processing restrictions If you have concerns regarding the accuracy of your Personal Data, you can ask the Company to limit the processing of your Personal Data. If you request that Personal Data be restricted, that 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 the 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 technically feasible. Your right to erasure is not affected by exercising 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 these grounds, or that the processing relates to the exercise, establishment, or defence of legal claims. 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 your Personal Data at any time. This won't affect the legality 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 set up 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 Member States may limit your rights in relation to Personal Data concerning you, as detailed in this section 13.

13.10 We will provide you with the requested information, as per the rights outlined in section 13 of this agreement, within one month of receiving your request. This time frame may be extended by up to two months if needed, depending on the nature and number of requests. Within one month of receiving your request, we'll notify you of any such extension and the reasons for it.

13.11 Provided it is not contrary to the provisions of section 13 of the law, the information you request under your rights in section 13 will be made available free of charge. If the request is unjustified or excessive, particularly where it is repeated, we may charge a reasonable amount to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.

13.12 If we have doubts regarding the identity of the person who submitted your request, we may ask that person to provide reasonable proof of identity.

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