GrowDirector Ltd. (also "We, "Our", "Us") is a grow controller that turns your plant cultivation into an automated process (the “Device”).
The aim of this Policy is to: (i) ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with; (ii) explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Platform; and (iii) explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
1. Collecting information on the Platform
- We may collect your personal data in the following ways:
- 1.1. Master data. When you create a profile on the Platform, we collect only your email address. The purpose of the collection of this information is to identify you as user when you log on to the Platform. This information is necessary, essential and mandatory for our ability to provide you with your personal right to use the Device and the Platform. We will not collect photos, precise Device or mobile device location, voice data, or other contacts or data from your Device without your prior consent. In this case you will always have the option to change your mind and withdraw your consent at any time.
- 1.2. Personal data collected that enables us to provide you with additional features/functionality. from time to time, you may also provide us with additional personal data or give us your permission to collect additional personal data in order to provide you with more features or functionality. Such collection shall be made only upon your prior and explicit consent.
- 1.3. From third parties. we may receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you better experience to our Services. We will use this personal data either where you have provided your consent to the third party or to us to that data sharing taking place or where we have a legitimate interest to use the personal data in order to be able to provide you with our products, features and Services
- 1.5. IP addresses and browser settings. When using the Platform, the IP address and the browser settings of your computer might be registered. The IP address is the numerical address of the computer used when visiting the Platform. Browser settings are, for example, the type of browser you use, browser language, time zone etc. The IP address and browser settings are registered to enable us to trace the used computer in case of misuse or unlawful actions in connection with the visit on or use of the Platform or the Device. Further, the IP address is used to derive your approximate location (on a city level).
- 1.6. Standard Internet Log Information. We use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to analyze and maximize the experience our users have in each part of the Services. This information is only used by us in a way which does not identify you
- 1.7. We do not collect other personal identifiable information from visitors of the Platform or users of the Device, unless the visitor expressly consented to provide the information to us.
2. Your rights and your preferences: Giving you choice and control
2.1. You may be aware that a new European Union law, called the General Data
Regulation or "GDPR" gives certain rights to individuals in relation to their personal data.
Accordingly, we have implemented additional transparency and access controls in our Privacy
Center located at: [Please refer to Privacy Center or any similar privacy page] to help
users take advantage of those rights. As available and except as limited under applicable
law, the rights afforded to individuals are:
- Right of Access: the right to be informed of and request access to the personal data we process about you;
- Right to Rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure: the right to request that we delete your personal data;
- Right to Restrict: the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object: the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to Automated Decision-making: the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
2.2. In order to enable you to exercise these rights with ease and to record
preferences in relation to how we use your personal data, we provide you with access to the
following settings via your Account Settings page:
- Privacy Center - allows you to control some of the categories of personal data we process about you, enables you to access your personal data via a ‘Download my Data’ button, and includes more information about how we use your personal data and what your rights are; and,
- Notification Settings - allows you to choose which communications you receive from us, manage your publicly available personal data, and set your sharing preferences.
- 2.3. The Privacy Center puts you in control of how we process your personal data. It provides you with information about what happens if you adjust your settings on your Account Settings page and how to opt out of receiving certain messages from us. If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from us (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you)
- 2.4. If you have any further questions about the General Data Protection Regulation, your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the ‘Contact Us’ form on the Privacy Center. We will respond to your request within a reasonable period of time upon verification of your identity. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with your local Data Protection Authority.
Disclosure of personal data
- 3.1. Please note that your consent to these guidelines implies that your profile on our Platform may not be anonymous.
- 3.2. We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymized format. We also may share your personal data in a pseudonymized format with our industry partners to help them understand how the content they license to us, to the extent any, is performing. We also share your personal data in a pseudonymized format with marketing partners who help us with promotional efforts and with advertisers that allow us to offer a free service.
- 3.3. We may be required to disclose information by a court order from a competent court of law or public authority in accordance with the existing legislation.
- 3.4. We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also will share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
4. Data controller
- 4.1. We shall be the data controller of the master data you enter in connection with your creation of a profile on the Platform. If you use a third-party service to create an account, we will receive personal data via that third-party service but only when you have expressly consented to that third-party service sharing your personal data with us.
- 4.2. The information for which you are the data controller. You shall be the data controller of the content you choose to disclose on the Platform and for the data disclosed on your profile which is the consequence of the connection of your profile on the Platform.
- 4.3. Links to the Platform. Our Platform contains links to other software, applications and sites. Note that by clicking such links you will be transferred to other applications, site or software Applications for which we are not the data controller. Thus, we would highly recommend that you always carefully read the personal data policies of these Mobile Applications, as their procedure and standards for collecting and processing personal data may be different from ours.
5. Security measures
We will use commercially reasonable efforts to see that the recorded data, including the personal information, under our control is handled using appropriate legal security measures and in compliance with any applicable laws and regulations.
We regularly audit the Platform and Device for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of information you transmit to us. Emails sent via the Platform are not encrypted, and we therefore advise you not to communicate any confidential information through these means.
- 6.2. The Platform may use session Cookies and persistent Cookies. We may also use similar technologies for storing and accessing information in the browser or device which utilizes local units and local storage, such as HTML 5 cookies, Flash and other methods. These technologies can operate across all your browsers. In some cases, the use of these technologies cannot be controlled by the browser, but requires special tools. We may use these technologies to store information to ensure the quality of reviews and to spot irregularities in the use of the Platform.
- Statistics. Measuring Mobile Application traffic, i.e. number of visits on the Platform, which domains the visitors come from, which pages the visitors visit on the Platform and in which overall geographical area the visitors are located.
- Improvement of the functionalities of the Platform: Optimizing your experience with the Platform, which includes remembering your email when you return to the Platform so you do not have to log in again.
- 6.4. Deletion of Cookies. You may be able to delete the Cookies already on your equipment. Deletion of Cookies shall be made in different technological ways, depending on the browser you are using. If you wish to do so, we recommend you to visit the support page for the browser in question. Please note that our Mobile Application will not work to its full extent if you delete the Cookies.
7. Access, correction and deletion
- 7.1. Access. Upon written request to us via the contact information stated herein, we shall inform you of the purpose of any processing made with your personal data; who receives the information and from where the information originates. Requests regarding the above shall only be processed if more than 6 months have lapsed since your previous request, unless you can substantiate a special interest in obtaining the information earlier.
- 7.2. Correction and deletion. If you discover that the information which we, as the data controller, process on you is incorrect or misleading, we shall make the correction hereof upon your request. We recommend that you - if possible - make the correction of such errors yourself.
- 7.4. When your profile is deleted, all the data associated with your user profile will be deleted within twelve (12) months, including your master data and reviews on the Platform.
- 7.5. We reserves the right to block the access to your profile and/or delete your profile, if the profile or the content of your profile on the Platform in our assessment is discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or in other ways violates the legislation, third party rights or the purpose of the Platform. If we block the use of your profile, you shall be informed hereon, as well as on the reason for blocking the access, by email to the address you have stated in your profile.
8. Keeping your personal data safe
- 8.1. We are committed to protecting our users’ personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems
- 8.2. Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Platform
- 8.3. Personal data collected within the European Union may, for example, be transferred to and processed by third parties located in a country outside of the European Union. In such instances We shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
9. Changes in the Privacy Polic